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Unbundled, untied and unmutualized The road to fiduciary
UNbundled, UNtied & UNmutualized: THE ROAD TO FIDUCIARY
What’s behind the increasing standards of care in the sale of life insurance.
By Richard M. Weber
One of the biggest trends in the sale of life insurance is the increasing demand for standards of care. Should all life insurance advisors be held to a fiduciary standard? Or is a suitability standard still acceptable? And how did we get to this point? Let’s take a look at the chain of events that resulted in advisors becoming more vulnerable to claims of negligence and bad faith.
Baby boomers will remember the popular “Father Knows Best” TV series that debuted in 1954. In the series, “Father” was a life insurance agent. Robert Young, the actor who portrayed “Father,” Jim Anderson, on TV gave voice to The American College’s founder Solomon Huebner’s admonition that a life insurance agent should be viewed as a professional, in the same way as a lawyer, accountant, engineer or clergyman. And that’s how Jim Anderson appeared to millions of mid-1950s viewers.
The satisfaction rating of life insurance agents has been in decline ever since.
When you follow the “Game of Life Insurance” path from the first U.S. life insurer, formed in 1759, through the proliferation of proprietary indices used since 2021 to enhance the appearance of indexed universal life policy illustrations, readers can begin to see a pattern of movements forward — and backward — of the issues that increasingly put insurance agents in peril of complaints and lawsuits about their sales actions and activities.
Largely evolving from the 1905-06 New York Armstrong Investigation, the industry had settled into selling life insurance to millions of Americans through industrial insurance (so-called debits involving the weekly payment of premiums with nickels and dimes) as well as through local, insurer-operated life insurance agencies. Those drawn to the industry for a career in insurance sales were vetted, completed a “Project 100,” and if accepted, received product and sales training from the agency — selling only for that insurer. The fictional Jim Anderson was a graduate of the process, as was I when I first entered the industry in 1967 as a senior in college.
In general, there was a strong ethic around prospecting, selling, servicing and compensation, the latter largely supported by compensation in the form of a “55 and nine 5s” commission structure, encouraging post-sale service by the agent who sold the policy. By the late 1980s, there were more than 2,000 life insurance companies in the U.S, but barely 10 years later, the number of carriers had declined to slightly fewer than 750, most often reduced through carrier acquisition or absorption of blocks of in-force policies.
Unbundled: A new development
1978 ushered in the most dramatic paradigm shift the industry had experienced in more than 200 years: the development of unbundled life insurance products. Featuring “transparent” elements of expenses and credits, these current assumption life products (almost immediately renamed universal life) allowed the customer to “pay what you want, when you want.” In the marketplace, this quickly transformed to “pay as little as you want, as infrequently as you want.”
In reflection, this paradigm shift occurred almost exclusively because of two external elements in the late ’70s and early ’80s. There were high interest rates because of an unprecedented level of inflation. This was the period with the introduction of a personal computer and printer that could display the extremely low calculated “premiums” one could pay when a 14% crediting rate was projected over a lifetime (yet, only momentarily sustained).
Before the UL Pandora’s box was opened with current assumption designs, whole life policies — with their guaranteed premiums on cash values, and death benefits — didn’t require a policy illustration to
convince the customer to buy. UL, on the other hand, was sold almost exclusively via a printed policy illustration that took, for example, the current crediting rate of 14% and used that rate to calculate the resulting cash value accumulations and the premiums to sustain the policy — to age 95 or 100. Few agents (and still fewer customers) recognized the fatal flaw of policy illustrations: Instead of sustaining for the next 40-60 years of average life expectancy, the current crediting rate would almost immediately begin falling (declining to the typical 4% guaranteed rate by the early 2000s).
Regulators would later require the term “premium” be used to describe the illustrated contribution to support the policy out of fear that agents would otherwise call it an “investment.” Billions of dollars were disgorged by the industry through class action lawsuits in the early to mid 1990s, in large part due to the industry’s failure to understand and communicate how the policies really worked.
Undone: Policies lapsed or were replaced
Roughly five years after UL was introduced, the percentage of new whole life policies in the marketplace had plunged from mid40% (the rest was term insurance) to 18%, and UL had escalated to achieve whole life’s former status as the biggest “seller” of lifetime death benefit products. Although this unprecedented level of disintermediation could have made sense to many consumers who weren’t interested in paying any more for their life insurance than they had to, declining crediting rates would cause many (if not most) policies to lapse or be replaced — due to projected policy failure long before life expectancy.
Untied: Training and supervision suffered
In part because of UL’s much lower profit margins as compared to those of the industry’s mainstay whole life products, prominent carriers as early as 1981 began withdrawing from the decades-old system of “tied agents” and local insurance agencies. The unintended consequences of untying would have an enormous impact on “ethics” in the sale of life insurance. Training — and especially local supervision — were often the first benefits to be lost as more and more carriers divested themselves of the “agency system.” The process of untying product “manufacturing” from distribution was accelerated in the late 1990s by such carriers as Transamerica, Pacific Life and Franklin Life.
History of Life Insurance Miscellany
Art borrows from life
Robert Young’s own life insurance agent was Frank Nathan, who suggested to his client that Jim Anderson’s career should be that of a life insurance agent. It was reasoned that it would be more natural for him to be seen around the house dispensing fatherly wisdom during “business hours.”
An unsustainable trend
Among the first to offer extremely high crediting rates, Kentucky Central Life’s 14% crediting rate effectively beat the competition. Of course, 14% couldn’t be sustained as current interest began declining throughout the 1980s, and the carrier slid into insolvency in 1993.
Recipe for failure
A supportable rate of 14% in 1980 needed to be reduced to 10% by 1985 and 7-8% by 1990, and policies purchased in the initial high-rate period were generally only crediting their guaranteed rate of 4% by the early 2000s. If the “premium” was never adjusted, the policy would fail decades before average life expectancy.
A first?
Anecdotally, Protective Life was the first such carrier to divest itself of tied agents beginning in 1981.
Failures explode
In “Insurer Failures GAO-92-44” from the Government Accounting Office, insolvencies of small regional insurers, which averaged just five per year from 1975 to 1982, more than tripled to 18 per year through 1988 and exploded to 47 in 1989 and 27 in 1990. Most were thinly capitalized insurers. That all changed in the 1990s, when insolvencies included some of the largest national insurers selling primarily low-margin, interest-sensitive products.
Jarring lapses
“Twenty-nine percent of permanent insurance policyholders lapse within just 3 years of first purchasing the policies; within 10 years, 57 percent have lapsed. In particular, nearly 88 percent of universal life policies, a popular type of permanent insurance, do not terminate with a death benefit claim,” according to “Lapse-Based Insurance” (Daniel Gottlieb and Kent Smetters, Olin Business School, Washington University in St. Louis and Wharton School, University of Pennsylvania, June 6, 2016. Updated and published in American Economic Review in 2021).
Unexpected: String of carrier failures
While there had been at least one notable carrier failure in the 1980s, many in the industry were shocked to learn of the July 1991 failure of Mutual Benefit Life, which was founded in 1845. This failure followed the failure of the less-traditional Executive Life just a few months earlier. The dominos continued to fall as the industry experienced the failures in 1994 of Confederation Life, Monarch and Kentucky Central.
Where did the agents go? The new industry of general brokerage agencies was greatly enhanced by agents (now independent brokers) seeking a “home” for sales support, access to multiple insurers, and especially high, negotiated commissions.
Some distressed carriers were able to avoid the pain and notoriety of failure by being acquired by other companies. The largest of those occurred when The Equitable became AXA in 1991 (not a good year for the industry).
Mergers included MassMutual absorbing Connecticut Mutual; the merger of Home Life with Phoenix Mutual; MetLife acquiring The New England
and, later, GenAmerica (which included General American Life); Prudential’s reinsurance treaty with The Hartford; and MassMutual’s acquisition of the inforce policies (and many career agents) of MetLife’s U.S. individual life operations.
On the “plus” side of all of this, the existence of state-run guarantee associations ensured that death claims (and annuity payments) were able to continue, even in the face of unprecedented financial stress on some life insurance carriers.
Unmutualized: Transformation to publicly owned
In this saga of the devolution of the life insurance industry, the other shoe was dropped when life insurance companies that dated back 150 years or more shed their identities and operating procedures as mutual companies and transformed themselves into publicly owned companies.
Some of the biggest (remaining) names in the industry joined the trend: Prudential, MetLife, SunLife of Canada, John Hancock, Union Mutual, Phoenix and Principal all began focusing on the needs of the shareholder above the exclusive needs of the policy holder — the intended focus of mutual carriers. Other demutualizations ended in the outright disappearance of several carriers, including Central Life, Royal Maccabees and Provident Mutual.
When I became a life insurance agent in 1967, I was told that “mutual” was the way God intended life insurance! Something valuable has been lost in the ensuing years.
The transformation from death benefits to “§7702 Plan” sales illustrations promising tax-free income far in excess of earlier contributions to “the plan” is just one more way the life insurance industry of Solomon Huebner’s era has strayed from the primary duty to protect widows and orphans from economic ruin.
Add premium financing to the proposals promising “free life insurance” and, we assume, free retirement income. The result is potentially disastrous for the clients.
Understanding: Unrealizable promises
With the preceding narrative as context, it is not difficult to draw some important and informative inferences. Products transformed from guarantees to unrealizable promises in the late 1970s. Also during this time, the method of selling those products became largely based on policy projections that were inherently unable to measure the effect of the subsequent rise and fall of in-force crediting rates for UL, variable universal life and IUL.
Acknowledging that life insurance companies needed to stay profitable, they managed this by divorcing their tied agents, leaving those agents to join brokerage operations that were often unskilled in the training and supervision the industry previously provided to maintain high standards of market conduct.
Carriers demutualized or were absorbed into bigger companies (or simply failed). In the face of still-falling interest rates, the remaining carriers devised newer and more complex methods of attracting customers.
Compensation methods changed as well, often allowing a broker to be paid all the compensation they would ever receive for the sale of a policy “heaped” in the very year in which it was sold (disincentivizing
The Game of Life Insurance
Follow the road from the industry’s infancy up to the modern day and the historical positive, negative and neutral influences on it.
1979 • CLU Society Code of Professional Responsibility.
1979 • Universal Life introduced — the first new type of life insurance in 100 years. 1980s • Rampant replacement — primary carriers and reinsurance companies begin to retreat from guaranteed premium select and ultimate annual renewable term insurance (or its graded premium whole life equivalent.)
1976 • ACLI — American life insurers form their own advocacy group. 1981 • Protective Life begins untying agents.
1759 • Presbyterian Ministers — first life insurance company incorporated in the U.S. 1871 • NAIC — Life insurance regulators join forces.
1905-06 • Armstrong Investigation — the New York State Legislature initiated an investigation of the life insurance companies operating in that state. 1928 • Society of CLU founded. 1974 • ERISA — set minimum standards for most voluntarily established retirement and health plans.
1954 • Father Knows Best — This TV sitcom introduced Americans to “Jim Anderson,” father, husband and life insurance agent.
1933 • Securities Act of 1933 — requires that investors receive financial information about securities being offered for public sale. 1940 • Investment Advisor Act of 1940 — defines the role and responsibilities of an investment advisor. 1990s • Class action lawsuits — insurers faced legal action over what policyholders claimed were misleading sales practices.
1996 • Guaranteed UL introduced.
policy service by the broker after the sale) and at commission levels “above street.” As far as it went, one could say that the industry stayed flexible and largely managed to survive a very stressful 40 or more years of economic change.
Unfortunately for those of us who have “seen it all,” much has been lost, and those losses have been particularly hard on clients. In an academic paper first published in 2016 and then updated in 2021, research conducted by professors Daniel Gottlieb and Kent Smetters of Washington University and The Wharton School at the University of Pennsylvania observed that nearly 88% of all UL policies ultimately would not sustain to the point of paying a death claim.
In those instances, any “gain” realized in the surrender of a policy would sacrifice the long-touted promise of tax-free accumulation and distribution of life insurance cash values.
Meanwhile, any gains would become immediately subject to ordinary income taxes — never mind the loss of the “inevitable gain of the life insurance policy held until death” — when a policy doesn’t fulfill that original intention.
The lifetime relationships pursued by the Greatest Generation’s Jim Anderson have today become largely transactional and “what have you done for me lately?” And in an often-used metaphor, the chickens are coming home to roost with an increase in civil and even class action lawsuits against agents and carriers.
As can be seen from the “Game of Life Insurance” timeline below, there are times of progress in the pursuit of client best interest and suitable sales — but also times where those aspirations are in decline. The efforts of The Society of Financial Service Professionals, the Certified Financial Planning Board, the New York State Department of Financial Services, the Department of Labor, the Securities and Exchange Commission and the Financial Industry Regulatory Authority have attempted to emphasize serving a client’s best interest and only recommending suitable products — those two standards sometimes positioned as a “fiduciary” duty.
When taken in the context of the 115 years since the start of the modern life insurance industry, there is progress.
Regulators regulate, but rules easily can be bypassed without a commonly agreed-upon ethos. The financial services industry’s awkward and tenuous move away from caveat emptor and toward fiduciary standards of care is a natural reaction to the issues reviewed herein. Let’s hope the efforts of these entities will prevail. Our clients are counting on us.
Richard M. Weber, MBA, CLU, AEP (Distinguished), is founder and president of The Ethical Edge, Pleasant Hill, Calif. He is a 25-year life insurance advisor, a 20year member of Million Dollar Round Table and served as adjunct professor of ethics at The American College. He may be contacted at Richard.weber@innfeedback.com.
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1980s • AIDS and viaticals — Some terminally ill policyholders are permitted to sell their life insurance policies to a third party.
1986 • Variable life products first become available.
1995 • Illustration Regulation — NAIC adopted regulations regarding how UL products are illustrated. 2010 • DoddFrank.
2008 • Rule 151A — requires registration of indexed annuities. 2010 • IMSA collapses.
2015 • DOL �� — Department of Labor proposes fiduciary rule.
2008 • CFP establishes Fiduciary Standard of Conduct for its members.
2003 • Premium Financing — New York State determines that a premium finance agreement is not an insurance contract.
2003 • Split Dollar rules — establish how split dollar arrangements may be taxed.
1996 • Insurance Marketplace Standards Association established. 1999 • STOLI — stranger owned life insurance is illegal.
1999 • Demutualizations — a number of mutual insurance companies became stock companies. 1999 • Glass-Steagall revoked — eliminated restrictions against affiliations between commercial and investment banks. 2015 • AG49.
2018 • AG49A. 2018 • DOL vacates fiduciary rule.
2019 • SEC Reg “BI.” 2019 • CFP Fiduciary.
2020 • NY 187 �� — New York State adopts best interest rule. 2021 • 40 years of declining interest rates.
2021 • NY 187 �� — New York rule overturned by appeals court. 2022 • Proprietary indices.
Financially empower your female clients
Advisors often misunderstand women’s approach to making financial decisions.
By Elke Rubach
Targeting female prospects is not just a marketing opportunity — it’s an opportunity to expand your business with more inclusivity and do what’s right. The way in which women make financial decisions is frequently misunderstood by or unknown to financial professionals. This can lead women to be hesitant to continue working with advisors. By changing your approach and personalizing your services and processes to meet your female clients’ specific needs, you can grow your clientele and create trusting, long-term relationships.
Tailoring your approach
According to a 2019 survey, 60% of women who were married or with a partner stated their financial planner treated their spouse or partner as the decision-maker. Not feeling acknowledged by their advisor can be a deterrent for many women seeking to cultivate a trusting relationship. Additionally,
87% of women said they cannot find a financial advisor to connect with, according to a 2015 survey.
Because the financial advising profession still views women as a niche market, advisors may be unaware of how to connect with their female clients or how to tailor advice for their female clients’ needs.
When you begin to work with female clients, it’s critical to speak to them as business professionals. Remain aware of their culture and background, and work to respect it. And from the beginning, be sure to provide advice to both partners individually.
Keep in mind that your responsibility to clients and their families includes taking a step back to guide them through the process. Although it may feel comfortable to assume general needs or concerns, be careful not to offer advice based on any assumptions — take the time to listen and ask questions about their needs. Depending on their answers and their specific goals, proceed with planning. Don’t start with solutions or by reverse-engineering a sale of a product. Cash flow planning, insurance and asset management all are important, but they need to be part of the plan.
Crafting the financial plan
Building a plan should be based on the client’s wants and goals — then, you can work toward finding the right solution. First look for the “what,” then figure out the “how.” Don’t assume your client’s insurance needs, or whether they know how to invest and run the numbers. Instead, ask about their style, their risk tolerance and their risk capacity. Asking questions to help gain a more well-rounded understanding of their financial background is beneficial as well. What is important to them? What have they tried? What worked? What didn’t? You’ll also want to dive deep into their spending habits.
The entire plan must be customized. It’s important to let your clients guide the conversation and to facilitate an environment where they feel comfortable asking questions. Keep in mind that most clients are interested in the journey just as much as they are interested in the destination.
When you do share a strategy with your clients, don’t make recommendations
without explaining the reasoning behind them. This can lead clients to lose interest in your business, as they might not feel your services can provide the support they need. Leverage the plan and math behind it to support any recommendations you make, especially about products. If you help clients with various intricate financial tools — such as sorting out wills, creating tax plans, and advising about insurance and investments — they will love and appreciate you. Finally, be strict about confidentiality. When clients become comfortable with you, they may open up and potentially become more vulnerable. Be careful not to discuss their fears or flaws with other parties. These are some suggestions, and you must learn how to read your client. Needs and goals change naturally at every step of a female client’s career — even at the beginning, when they might not be When clients become comfortable with you, they may open up and potentially become more vulnerable. deemed a “profitable” client by others. So you will likely be on track to have a very long-term, loyal relationship. Remember, you hold the key that gives meaning to their years of work and sacBe careful not to discuss their fears or flaws with other parties. rifice in the name of breaking the glass ceiling. Take the necessary steps to educate and uplift the women you’re serving. In a nutshell, make sure they know you truly care.
Elke Rubach, LLM, CFP, CLU, a five-year MDRT member, speaks about wealth management, estate planning and philanthropy. She may be contacted at elke.rubach@innfeedback.com.
Will our money last through retirement?
Four suggestions to help extend income for the length of the post-employment years.
By Ike S. Trotter
Today, many of our most recognized celebrities are hitting life’s “milestone” birthday of age 65 and joining the ranks of “senior citizens.” Just to name a few, Vanna White of “Wheel of Fortune” just turned 65. Donny Osmond, practically a toddler when he performed and sang on “The Andy Williams Show,” will turn 65 this month. Add another year and you include Tom Hanks, Bill Gates and Joe Montana, who are turning 66 this year.
At this age, they are now eligible for full retirement age benefits with their Social Security income. And how is it possible that Ron Howard, who played Opie on “The Andy Griffith Show,” is now age 68?
October is National Retirement Security Month, making it the perfect time for financial professionals to review retirement planning strategies for both themselves and their clients. In my experience, I’ve found a few basic keys to ensure that we and our clients don’t outlive our retirement savings.
All this leads to the real crux of retirement planning today, and that is having enough income. However, the most important aspect of retirement planning deals with a key longevity question, which is how long must this income last?
Today, you can surf the web and find thousands of internet platforms offering calculators that can estimate how long you will live. I recently answered questions through two of these programs, the first being through Northwestern Mutual life at their website media.nmfn.com/lifespan.
Through a series of questions, it calculated I could live to age 93.
The second was a website on exercise and longevity called blueprintincome.com/ life-expectancy-calculator, which estimated I would live to age 94. While I like what these programs have estimated for me, the larger, unanswerable question from this exercise could be will I have enough money at my retirement to last a lifetime? And when we are looking out for our clients’ interests, it is important that we consider the same question on their behalf.
None of us has the exact answer, but we are seeing trends that potentially illustrate needing retirement income for years and years. One of the most incredible statistics is that for every American worker retiring at age 65 today, there is now a 50/50 chance of their making it to age 90! And with a life span stretching over several decades at retirement age, it is possible they and we would come up short on cash.
So, what can be done? What must happen to generate enough income to support our golden years, which may stretch longer than our childhood? A tough question for sure, but here are four suggestions that may help extend income a bit further in retirement: » Probably most important is creating a retirement budget. Transitioning from active income to retirement income is not easy. Critical to this is discerning between essential income and discretionary income. Understanding the differences between the two is essential. » Be careful about retirement withdrawals. Particularly for plans such as individual retirement accounts or employer-sponsored 401(k) programs, this means not withdrawing too high a percentage of income. A withdrawal percentage of 4% or even 3% provides a better chance of your account lasting over a lifetime. Even if your holdings can achieve a 5% or 6% overall yield on assets, it is wise to build a backlog of extra earnings that can accumulate and be available to offset the damaging effects of inflation. » Consider delaying your retirement income. A good example would be your
Social Security. For every year you delay claiming benefits past normal retirement age, your monthly benefit can increase by some 8%. And if you can delay beginning Social Security from age 66 to age 70, your potential monthly income stream can grow by some 32% more. » Finally, consider annuitizing a portion of your retirement assets into an income stream. In addition to guaranteeing a lifetime income, the potential for a larger payout is enhanced because both principal and interest are being distributed.
White Osmond Hanks Gates Montana Howard
Ike S. Trotter, CLU, ChFC, operates the Ike Trotter Agency in Greenville, Miss. He may be contacted at ike.trotter@innfeedback.com.
Consumer concern shifts from COVID-19 to the economy
Confidence in life insurers and agents remains high.
By Jennifer Douglas
For nearly two years, consumer concerns about COVID-19 and the economy went hand in hand. However, the two concerns diverged more recently as fears about the virus waned this year and the flailing economy took center stage.
LIMRA’s quarterly Consumer Sentiment in the Time of COVID-19 study found only 29% of Americans expressed a high level of concern about COVID-19 in July 2022, down from 50% just six months earlier. In contrast, 63% of consumers said they were highly concerned about the economy. This is 13 percentage points higher than at the beginning of the year. Only 15% of adults have a favorable opinion of the economy today, the lowest sentiment we’ve captured during the pandemic.
Understandably, people with high levels of stress over their household finances (74%) and those anticipating increased financial stress this year (85%) expressed the most concern about the economy.
With inflation at its highest level since 1982, virtually every American is concerned about it to some degree. Inflation appears to be a prime driver behind the anticipation of increased financial stress. Nearly 9 in 10 people who expect their financial stress will increase (further) in 2022 say inflation is a major concern.
In recent months, a majority of Americans have taken action in response to the current economic climate. Nearly 9 in 10 adults took favorable actions — steps that are likely to improve their financial stability and security — such as being more budget conscious, saving or investing more, and taking steps to increase their income. In an effort to make ends meet, however, nearly 3 in 5 adults have taken “unfavorable actions” that can be more detrimental in nature, such as saving less, increasing one’s improve this year. At the same time, very few adults say poor economic conditions would motivate them to buy life insurance in an effort to reduce their risk (1%).
Levels of confidence in various segments of the financial services industry have dipped since January, but are similar to where they were before the pandemic, in January 2020. Nearly 1 in 3 Americans has “quite a bit” or an “extreme amount” of confidence in insurance companies today, and nearly 9 in 10 have at least “some” confidence.
Consumer confidence in insurance agents and brokers accelerated during the pandemic and remains higher than levels consumers felt at any time since the 2008 Great Recession. Confidence in financial advisors also improved significantly during the pandemic and is well above pre-Great Recession levels.
Given consumer confidence in our industry, the current economic uncertainty provides the perfect opportunity for life insurance carriers and advisors to educate consumers about the importance of life insurance and the financial security it can provide for today and for generations to come.
Consumer Actions With Spending Due to Economic Conditions Consumer Actions with Spending Due to Economic Conditions
Cut back on dining out/entertainment
Change shopping habits (e.g., scale back, buy generic)
Drive less
Put off a major purchase
Cut back on subscriptions or memberships
Change or cancel vacation plans
39%
33%
37%
28%
36% 47% 49%
49% 60% 62%
58% 59%
Source: LIMRA
Have taken action in recent months Likely to take/continue taking action in 2022 if economic conditions persist
debt, cutting back on retirement contributions or skipping medical care.
Most consumers have made changes to their spending in recent months. The most common include cutting back on dining out or entertainment, changing their shopping habits, and driving less. Other changes, such as putting off a major purchase, canceling subscriptions or memberships, and changing or canceling vacation plans are likely to increase if economic conditions don’t improve.
Household finances top the list of what’s causing stress today, followed closely by work. Both have reached or surpassed their pre-pandemic levels. Half of adults expect their level of financial stress to remain about the same over the next six months, while a quarter expect it to worsen and a quarter expect it to improve.
Other LIMRA research shows that people who own life insurance feel more financially secure. Two-thirds (68%) of life insurance owners report that they feel financially secure, as compared to 47% of non-owners. Although consumers in the current study are making some difficult choices with their finances, very few (only 1%) say they’ll be likely to reduce or cancel their life insurance coverage or put off buying coverage they feel they need (2%) if economic conditions don’t
Jennifer Douglas is research director, member benefits quality and performance, LIMRA. Jennifer may be contacted at jennifer.douglas@innfeedback.com.
