Robert E Wilcox

“Second, it was observed that ….. there is virtually no accountability for any of the participants in the sale, not for the company, not for the agent, and interestingly, the white paper discussed accountability on the part of the purchaser as well.”

–Robert E. Wilcox – Chairman of the Life Disclosure Working Group (NAIC)

1994, PROBLEMS AND SOLUTIONS FOR PRODUCT ILLUSTRATIONS, Society of Actuaries

“Commissioner Wilcox said that he admitted that the working group <Life Disclosure Working Group> had gotten a little sloppy on its terminology, but it had been clear all along that the working group was focusing on sales.”

1996-4V2, NAIC Proceedings

Mr. Robert E. Wilcox: Do not expect consistent answers from the panelists because we are still talking this through, and I can assure you that we are far from reconciling this issue in our own minds, let alone with each other.

1996 – Nonforfeiture Law Developments, Society of Actuaries – 23p

“We have to get out of our mode of talking about these policies in language that can only be understood by the person who wrote the language. I find, after 30 years plus of experience in the life insurance business, that there is jargon used in illustrations that I don’t understand. I can have difficulty in taking an illustration and figuring out what in the world the authors are trying to illustrate and how they are doing it.” ——–Robert E. Wilcox – Chairman of the Life Disclosure Working Group (NAIC)

1994, PROBLEMS AND SOLUTIONS FOR PRODUCT ILLUSTRATIONS, Society of Actuaries

I think it is. If we are going to have a group of consumers of our products who are satisfied with what they get, we have to meet their expectations.

Obviously, there are two adjustment points whereby that can be accomplished.|
– One is that you can change the outcome to match the expectations.
– The other is to change the expectation to match the outcome

1994, PROBLEMS AND SOLUTIONS FOR PRODUCT ILLUSTRATIONS, Society of Actuaries

When I attended the first meeting, I very much wanted to repent and take a different course. I sensed that, even though this was a problem that I had observed over a long period of time through my consulting practice, the regulators and the industry were reaching for answers in a very difficult circumstance.

it was important to observe that these nonactuary regulators, experienced, competent people, were seeing a different set of problems than we, as actuaries, were used to focusing on.

I’ll try to help in the course of our discussion to bring that up from time to time. Their focus was emphasizing understandability much more than supportability. It is important to understand that we as actuaries focus on the supportability issue. What I was hearing almost exclusively was understandability.

1994, PROBLEMS AND SOLUTIONS FOR PRODUCT ILLUSTRATIONS, Society of Actuaries

Commissioner Wilcox also spoke favorably of a new provision in California where the illustration of non-guaranteed elements must show the lesser of the amount being currently paid, the amount the company is currently earning, or the amount the company can expect to earn.

1994-3 NAIC Proc.

John Montgomery (Calif.) said that complicated products are not understood by the typical applicant.

Commissioner Wilcox said that a “typical applicant” for a sophisticated policy should be a sophisticated applicant, and he acknowledged that the wording might need to be clarified in that instance.

1994-3 – NAIC Proceedings

ATTACHMENT ONE-A1

TO: NAIC Members

FROM: Robert E. Wilcox, Chair, Life Disclosure Working Group

DATE: January 21, 1996

RE: Life Insurance Illustrations Model Regulation

In December the NAIC membership adopted a new Life Insurance Illustrations

Model Regulation to address some of the problems we have all been

experiencing as consumers complain that their “vanishing” premiums haven’t

vanished and the high returns they expected haven’t materialized.

1996-1 NAIC Proc.

1994 – PROBLEMS AND SOLUTIONS FOR PRODUCT ILLUSTRATIONS – 28p, Society of Actuaries