Date:January 6, 2009
To:All Life Insurers Transacting Business in Wisconsin
From:Sean Dilweg, Commissioner of Insurance
Subject:Determining Minimum Standards for Funeral Policies under Section 632.415, Wis. Stat.

Section Ins 2.81, Wis. Adm. Code, sets forth the requirements for the use of the 2001 Commissioner's Standard Ordinary (CSO) Mortality table in accordance with s. 623.06, Wis. Stat., s. 632.43, Wis. Stat., s. Ins 2.80 (4) (a), Wis. Adm. Code, and s. Ins 2.80 (4) (b), Wis. Adm. Code. Section Ins 2.81 (4) (a), Wis. Adm. Code, (2001 CSO Mortality Table Effective Dates) provides that the 2001 CSO Mortality Table may be used as the minimum standard for policies issued on or after January 1, 2005, and before January 1, 2009, and shall be used in determining minimum standards for policies issued on or after January 1, 2009. Section 632.415, Wis. Stat., regulates "funeral policies" which are defined as a life insurance policy that provides for the "assignment of the proceeds of the policy to a funeral director or operator of a funeral establishment if the insurance intermediary who sells or solicits the sale of the policy is not an agent of the funeral director or operator of the funeral establishment or if the assignment of proceeds is contingent on the provision of funeral merchandise or funeral services as provided for in a burial agreement that satisfies the requirements of s. 445.125 (3m) and rules promulgated by the funeral directors examining board under s. 445.125 (3m) (j) 1. b."

The purpose of this Bulletin is to advise life insurance companies that, effective January 1, 2009, the 1980 CSO Mortality Table may continue to be used in determining the minimum standard valuation of reserves and the minimum standard for nonforfeiture values for funeral insurance products. The department intends to promulgate amendments to s. Ins 2.81 (4), Wis. Adm. Code, to address this matter which will appear on the department's Web site at

Insurers are further advised that if the mortality rates from the 1980 CSO Mortality Table are used for nonforfeiture and valuation, they must also be used for compliance with s. 632.415, Wis. Stat. (Funeral Policies).

Questions regarding this Bulletin should be directed to John Kitslaar at