Brenda Cude

? How much do the benefits build up in the policy?

? How will the timing of money paid and received affect interest?

2018 – LIBGWG – Cude Letter / Markup Life Insurance Buyer’s Guide – Revised 2-9-18 for discussion on conference call 2-22-18

  • 2016
    • 4/3 – ACLI (ML) narrow the charge, BC- all products (Market Conduct / Lawsuits)
  • 2017
    • 11/6 – AAA – NGE’s, BC – NGEs ….not something the average consumer would understand.
    • approx. 11/17 – BC – Call Universal Life Permanent
  •  2018
    • 2/22 – What Benefits? What Interest?
Have the right info?
Retirement Security WG – NAIC isn’t best place for Education

2016

2016/4/3, NAIC Proceedings, LIIIWG CC,

Mr. Lovendusky said the ACLI work group discussed whether the charge should include revising the Buyer’s Guide, which was a suggested addition to the charge from the American Academy of Actuaries (Academy).

While the ACLI work group did not oppose including the Buyer’s Guide, some on the work group thought that revisions to the Buyer’s Guide might work instead of revisions to the models.

However, Ms. Cude pointed out that the Buyer’s Guide has a different purpose from the policy summary and that revisions to one would not take care of the other because the Buyer’s Guide is designed to be educational, while the policy summary is informational and explains a particular policy.

“He <Michael Lovendusky – ACLI> said consumers are mostly confused about options, guarantees and riders.

The ACLI work group was considering asking the Life Insurance and Annuities (A) Committee to narrow the charge to look at only products with options, guarantees and riders, but Ms. Cude said she thinks that it is important to consider how the disclosures for all products could be improved.

2016-3, NAIC Proceedings
Brenda Cude (University of Georgia) offered to assist the Working Group with drafting consumer-friendly language once the content has been decided.

2017

“Thank you for the clarification you provided in our recent conference call about the target market for the draft life insurance buyer’s guide.

With that in mind, we started by making a list of basic information about life insurance that first-time buyers probably don’t know.”

“We didn’t find any scholarly research on the topic but did find references to a number of industry-sponsored surveys.”  

2017, July 19 – Consumer Reps letter to Mary Mealer, Chair Life Insurance Buyer’s Guide Working Group, From: Brenda Cude, Karroll Kitt, Birny Birnbaum

2017/11/6

Life Insurance Buyer’s Guide (A) Working Group

Conference Call

Attachment Four

Life Insurance and Annuities (A) Committee

 

Brenda Cude (University of Georgia) said the issue of NGEs is interesting, but not something the average consumer would understand.

She did not think it was information that was appropriate for a short guide for first-time purchasers. Karrol Kitt (University of Texas—Austin) agreed with Ms. Cude. 

Ms. Mealer also agreed that this was an important topic probably best addressed in the online tool.

 

No Date
Assuming approximately
11/15/2017

 

  

Comment [BJC2]: Permanent insurance is a term used only by the industry – not by consumer educators.

We would prefer – Life insurance comes
in two basic types: Term and whole life (also referred to as permanent insurance).

2018

? How much do the benefits build up in the policy?

? How will the timing of money paid and received affect interest?

2018 – LIBGWG – Cude Letter / Markup Life Insurance Buyer’s Guide – Revised 2-9-18 for discussion on conference call 2-22-18

2019

  • <1> We want you to know that Financial Education is important, but that many other groups are better situated to design deliver and evaluate education than NAIC is.  
  • We think NAIC’s most important role in Retirement Security is to make sure that consumers can safely buy well-designed insurance products in stable insurance markets.
  • … NAIC should focus it’s efforts on consumers who have fewer resources.
  • <3> 4th Graders / 12th Graders
  • Teachers are going to teach what they know and what they are interested in and Insurance will be one of the items that gets short changed….
  • So….. this concept of Just in Time education ….suggests that it will be most effective after high school.
  •  

— Brenda Cude

  • Knowledge lets consumers make rational decisions…
  • However, as I say often, consumers do not make rational decisions….
  • We know that knowledge is necessary to make a plan… so, that we can get the security we want in our lives.
  • Our attitudes, our beliefs… they really come from our life experiences and they point us to different actions…

 

  • National Endowment for Financial Education Task Force (College Level)

  •  
  • Teachable Moments

2020/1/ – RETIREMENT SECURITY Conference Call – NAIC, Cude / Kitt Presentation

Attachment

Financial Advisor Characteristics and Quality of Advice: Fiduciary and
Suitability Standards of Care
Joseph E. Goetz44, Ph.D., Swarn Chatterjee, Ph.D. & Brenda Cude, Ph.D., University of Georgia
Key words: client communication, ethics, fiduciary, financial advisor, financial planner, professional standards,
standards of care, suitability

https://www.afcpe.org/wp-content/uploads/2019/05/2015-Proceedings-Final-1115.pdf

“Brenda Cude (Cooperative Extension Service) opined that the target audience  soes not care about assumptions.”

 

NAIC Proceedings 1996 3rd Quarter Vol. II 931

ATTACHMENT THREE-B1 Report of the Cost Indices Subgroup of the Life Disclosure (A) Working Group

 

References

1997 – What Does it Mean to be a Consumer Representative? – Brenda Cude – 3p 

“In 1994 I was selected as a funded held. In these meetings, groups work consumer representative to the on specific charges they have identified National Association of Insurance or that have been assigned to them by Commissioners (NAIC).”

“In reality, much of what NAIC consumer representatives do to
represent consumers is to educate regulators.”

“If regulators learn about issues only by listening to the industry, their knowledge is unquestionably biased.”

The other board members agreed and upon motion duly made and seconded, the board voted to appoint Ms. Cude to the two-year term as a consumer representative to the Consumer Participation Board of Trustees.

1996-1

Brenda Cude (University of Georgia) suggested the Working Group not worry about the language or format at present, but
focus on what should be included for content and suggested including charts and tables. A lower reading level should be used
and not include any jargon. Ms. Cude provided a brief overview of the focus group information Mr. Birnbaum mentioned
earlier. PROPERTY AND CASUALTY INSURANCE (C) COMMITTEE
Consumer Guides (C) Working Group
Conference Call
September 5, 2007
Ms. Cude reminded the Working Group that she and Ms. Kitt provided the Working Group in March 2007 with a
summary of various states guides and various concepts the states had on their websites.
  • Dr. Brenda Cude (University of Georgia) said disclosures are not a summary that tells policyholders what is in the contract;
    rather, a disclosure is a document that directs a policyholder’s attention to specific information they may need to know.
  • Ms. Cude said the issue of good disclosures is about much more than readability; it is about more effective communication.
  • Ms. Cude asked that the NAIC and the Working Group look at the issue in general and develop a recommendation with regard to readability standards.
  • Mr. Lisson said Flesch scoring measures readability from the standpoint of word choice and sentence structure, but cannot assess whether the text being analyzed provides the reader with the necessary information to help him/her understand the insurance disclosure or policy.
    5. Receive Brief Update on Consumer Information Source (CIS) Suggested Wording
    Mr. Lisson said regulators from Colorado, New York and North Carolina and Dr. Brenda Cude are currently working on
    recommendations for simplification of the wording on the NAIC Consumer Information Source (CIS) Web page. He added
    that the recommendations will also include revisions to some of the statistics and how they are calculated. He said a draft
    document is currently circulating among the individuals working on this issue. Ms. Baker said her concern is that the
    language used on the CIS Web page does not match the content of the market analysis-related sections of the Market
    Regulation Handbook. Mr. Belo said this issue is not yet final and will continue to be analyzed by the individuals charged
    with this project.

  • 2009 – NAIC Proceedings -Market Regulation and Consumer Affairs (D) Committee – Consumer Connections (D) Working Group Washington, DC, September 22, 2009

Both Brenda and Bonnie are frequently called upon by state legislatures and state insurance departments, as well as numerous NAIC members, to offer consumer perspectives at public hearings and conference calls, as well as interim and national

meetings. 2015-03

Brenda Cude said the Buyer’s Guide needs a total overhaul, not just a revision.

She explained that the products in the marketplace have radically changed since the time the Buyer’s Guide was first written. 2016-1

 

The use of the term “prices” versus “premiums” is inconsistent throughout this document, so Ms. Cude said she will go through the document and replace “prices” with “premiums.” The Subgroup agreed to these changes.  2016-1

Brenda J. Cude (University of Georgia) commented that there are agents and brokers not doing a good service to consumers and that educating the agents and brokers is important.

Attachment Four-F

Senior Issues (B) Task Force

2016-2, 8/26/16 -ltc

Brenda J. Cude (University of Georgia) said the benefits of the DOL fiduciary rule to consumers are that it will help to align

the interests of advisors with those of their clients; it will encourage consumers to have greater trust in advisors; and it will

lead to greater consumer demand for advisor services. Ms. Cude said many consumer groups—such as AARP; Consumer

Federation of America; Americans for Financial Reform; the American Federation of Labor and Congress of Industrial

Organizations; the American Federation of State, County, and Municipal Employees; and the Pension Rights Center—

representing tens of millions of consumers, support the DOL fiduciary rule.

2016-2, NAIC/Consumer Liaison Committee, San Diego, California, August 28, 2016

Karrol Kitt (University of Texas at Austin) said that she and Brenda Cude (University of Georgia) suggest that the first thing

that should be decided is the purpose of the buyer’s guide and whether it should be paper or electronic. 2016-3

Brenda J. Cude (University of Georgia) said that, in order to determine how helpful state insurance department websites are to insurance consumers, NerdWallet did a survey in the fall, the purpose of which was to lookup financial resources, not just insurance resources.

Commissioner Lindeen said the ranking for Montana should be higher than it is currently.

Ms. Bach said the state could contact NerdWallet to challenge its respective rankings

2016-3, NAIC/Consumer Liaison Committee, Miami, Florida, December 12, 2016

  • Mr. Gendron asked Ms. Cude what she thinks of including information about the use of life insurance in estate planning. Ms. Cude said she thinks that consumers who are interested in that topic should be urged to seek the guidance of a qualified expert.
  • Brenda Cude (University of Georgia) said an interactive online cost calculator would be helpful, but not a  static form in an online PDF file or hardcopy format.
  • Brenda J. Cude (University of Georgia) said that form and format are as important as content…..

2017-1

 

Ms. Cude said there is a tension between creating a comprehensive guide and making sure it is useful for consumers. She said the electronic format allows more information to be included because it is not available all at one time, and is less overwhelming than if the same information were provided in a booklet. Ms. Cude suggested focusing on an electronic tool and also creating a more streamlined printable version. Director Ommen said the Buyer’s Guide should be short and tailored to address more typical issues and could include a reference to other resources to get additional information.

2017-2, Attachment One-A, Life Insurance and Annuities (A) Committee, 8/7/17

Dr. Cude asked about the intended audience, or not the intended audience, for this document. She said the document appears

to be for professionals and not consumers. Commissioner Miller replied that the document is geared toward professionals,

policymakers, the press and similar entities. She said she envisions the states taking the document and creating a consumerfriendly

version for consumers. Ms. Burns said there is a deficit of information about these products in the document.

2017-2, Attachment Two, Senior Issues (B) Task Force, 8/6/17

  • 4. Heard a presentation from Karrol Kitt (University of Texas at Austin) and Brenda J. Cude (University of Georgia) on maximizing states’ use of resources to better serve consumers.
  •  

2017-3

  • Brenda J. Cude (University of Georgia) said there are similarities and differences between consumer guides and shopping tools. She said consumer shopping tools are more specific than consumer guides….

  • Ms. Cude said the Privacy Disclosure as well as the SBC are both examples of how consumer testing can be useful in developing consumer shopping tools.

  • She said going forward, the NAIC can move toward smart disclosures that consumers can input personal data specific to their insurance needs in order to pinpoint the insurance product that will be the best fit for that particular consumer.

  • She said the Working Group collected numerous resources on this topic that may not be readily available on the NAIC’s website.   Ms. Cude suggested that an NAIC web page be created specifically to house these types of consumer services in one place and to enhance the current use of these resources by states leading to additional success of these resources in helping consumers.

  • 2017-3, NAIC/Consumer Liaison Committee, Honolulu, Hawaii, December 4, 2017

She <Mealer> said an additional outline of topics (Attachment Four-B) submitted by Brenda Cude (University of Georgia) had been posted on the Working

Group’s web page.   

2019-1, Life Insurance Online Guide (A) Working Group, Conference Call, March 18, 2019

+++++++++++++

Transparently Opaque: Understanding
the Lack of Transparency in Insurance
Consumer Protection
Daniel Schwarcz

https://www.naic.org/cipr_newsletter_archive/vol6_consumer_viewpoints.pdf

See Brenda J. Cude & Daniel Schwarcz, Consumer Viewpoints on Effective Disclosures, CIPR
NEWSL. (Nat’l Ass’n of Ins. Comm’rs & Ctr. for Ins. Policy & Research, Kansas City, Mo.),
Jan. 2013, at 26, 30, available at http://www.naic.org/cipr_newsletter_archive/vol6_
consumer_viewpoints.pdf (noting that regulator-designed disclosures create consistency across
firms, making comparisons easier for consumers);
See Public Hearing on Insurance Contract Readability Standards Before the NAIC
Consumer Connections Working Group for the Public Hearing on Insurance Contract
Readability Standards (Mar. 2010) (testimony of Brenda Cude, Prof. of Hous. & Consumer
Econ., Univ. of Ga.) (on file with author).
See Public Hearing on Insurance Contract Readability Standards Before the NAIC Consumer
Connections Working Group for the Public Hearing on Insurance Contract Readability
Standards, supra note 146 (testimony of Daniel Schwarcz, Brenda Cude, and Amy Bach).