Variable Insurance

Variable Insurance

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When it comes to the complex environment of variable insurance products, the SEC and FINRA test practices heavily for activities that exploit client vulnerability such as:

  • Unsuitable sales and switching, especially to senior citizens
  • Failure to disclose critical information to customers
  • Improper sales contests
  • Failure to maintain and enforce adequate written supervisory procedures designed to prevent or detect abuses in the above areas

ACA helps insurance companies and distributors understand and manage these complex compliance requirements and develop and implement the comprehensive, effective risk-based protocols necessary to meet regulators’ expectations.



ACA provides the following to help life insurance companies and VIP distributors ensure compliance.

Compliance and Supervisory Program Reviews

  • Mock SEC VIP back-office administrative examinations
  • Rule 38a-1 annual compliance reviews for insurance company and service providers
  • Outsourced “internal audit” function appraisals, including Rule 3010 reviews
  • Licensing, registration, and insurance appointment procedure reviews
  • AML VIP and Rule 3011 independent testing/review

Other VIP Offerings

  • Assessment of surveillance and monitoring program guidelines and the adequacy of risk-based parameters
  • Development of customized written supervisory, desktop operating, and surveillance procedures
  • Review of compliance program design and effectiveness of existing operating procedures
  • Development of customized suitability forms and suitability guidelines, including sales to seniors, rider guarantees, replacements, and investment objectives
  • Evaluation of the adequacy of existing staffing and technology resources
  • Onsite SEC or FINRA inspection support
  • Advertising and sales literature reviews
  • Regulatory-mandated consulting
  • Insurance company business unit and compliance training
  • Supervisor and representative compliance training
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