Date:May 5, 2008
To:Insurers Selling Life Insurance or Annuities and
Insurance Producers Doing Business in Wisconsin
From:Sean Dilweg, Commissioner of Insurance
Subject:Improper Use of Certain Designations/Titles Targeting Senior Purchasers

The use of senior or retirement specific designations and titles by insurance producers in the marketing and sales of individual life insurance and annuities directed to seniors has increased nationwide. The use of titles, with words such as "certified," "accredited," "retirement planner," "senior advisor" or "senior consultant," implies special training or education for selling specialized products to seniors. However, this may not be true. The use of certain designations may mislead seniors who are considering purchasing life insurance or an annuity from an agent or company into thinking that special courses or exams were passed and signify expertise in seniors' financial matters, when, in fact, no such expertise exists. Some designations may have little or no educational requirements.

This bulletin applies to the marketing and sales of all life insurance and annuities, and requires the proper use of designations by producers.

Section Ins 2.16, Wis. Adm. Code, Advertisements of and deceptive practices in life insurance and annuities, provides for the regulation of the advertising of life insurance products and annuities. Insurance companies are responsible for all advertising for their products whether the advertisement is prepared by the company or the producer. The inclusion of designations in an advertisement is considered part of the advertising of the product.

Any producer who advertises himself or herself as holding special status due to training or advanced education must be able to provide documentation of expertise, such as a course syllabus and proof of successful completion of the course of study or training. No producer should hold himself or herself out through the use of designations or credentials as possessing special knowledge or expertise relating to retirement or the senior market, unless such designation or credential is supported by a documented program of study.

If producers misrepresent their level of expertise in marketing and sales activities, they will be subject to penalties under state law. An insurer who allows its producers to use misleading designations will also be subject to penalty under state law.

The following is a partial list of the recognized programs of study which have had courses approved for continuing education credit in Wisconsin.

Recognized Programs of Study:

Chartered Financial Consultant
Chartered Life Underwriter
Life Underwriter Training Council Fellow
Certified Employee Benefit Specialist
Registered Health Underwriter
Certified Financial Planner
Fellow of the Life Management Institute
Registered Employee Benefits Counselor
Health Insurance Associate
Certification in Long-Term Care
Fraternal Insurance Counselor

Contact Information:

Mike Honeck - Chief of the Health and Life Insurance Section
mike.honeck@wisconsin.gov