LEGAL & GENERAL NETWORK PROTECTION AND GENERAL INSURANCE … · INSURANCE ADVICE STANDARDS...

Protection & General Insurance Advice Standards

1 Protection and General Advice Standards V15 09/12/2013

LEGAL & GENERAL NETWORK

PROTECTION AND GENERAL

INSURANCE ADVICE STANDARDS

(non-investment contracts)



CONTENTS

1.0 INTRODUCTION AND STANDARDS OVERVIEW

3.0 RECOMMENDING 4.0 APPLYING 5.0 DOCUMENTING 6.0 REFERRING (TO THE CENTRAL ADVICE UNIT)

GLOSSARY

INDEX ANNEX A – MANDATORY PRODUCT DISCLOSURE GUIDANCE

2.0 FACTFINDING ANNEX B – POLICY

SUITABILITY GUIDE

Any queries in relation to these standards should be directed to the Business Support Team 0845 070 1303 option 1 or email

[email protected]. We are here to help you, and want to ensure that you understand the

requirements of this document so that our mutual customers get the most suitable advice to fit their needs and circumstances.

ANNEX C – AIMS AND VIEWS SCREENSHOT



1.0 INTRODUCTION AND STANDARDS

OVERVIEW.

The protection and general insurance advice standards reflect the FCA and Legal & General requirements for advising on protection policies. It encourages the application of customer centric behaviours as defined in FCA handbooks Treating Customers Fairly handbook (TCF), and the wider principles (PRIN). Content These standards use ‘Fundamentals’, ‘Not Permitted’ areas and ‘Exceptions’ to assist you in following Network and FCA

rules as closely as possible.

‘Fundamentals’ cover the core Legal & General Network (hereafter known as The Network) requirements and

regulatory rules which must be followed. Failure to do so may result in a Sales Quality failing, a Network rule breach, or even a Regulatory Rule breach. Any breach of these fundamental rules should be declared to your firm’s PoCC (or line manager and/or T&C Oversight team for LGFS and FSD). Some items may not be relevant to customer situations, others will. The extent of their significance to a particular case could depend upon an individual customer’s circumstances and financial awareness. Any discussions relevant to the advice given MUST be summarised in the Protection Suitability Letter (PSL).

‘Not permitted’ areas, signified by a red cross, contain examples of what you cannot do, as it will result in a breach of

regulatory and/or Network requirements.

‘Exceptions’ are those situations that may mean that a fundamental rule may not be relevant, or may require you to

adopt a different approach to that documented. This does not mean that they are not fundamental, however. Additional Business Areas

Where this document uses the term ‘adviser’, LGFS and FSD should read ‘consultant’. Additionally, where it says ‘firm’, LGFS and FSD should read ‘Legal & General’ or department/associate name.

Requirements

You, as an adviser of Legal & General or the Network, have a regulatory responsibility at all times to:

Act in the customer's best interests when giving advice

Ensure that the documentation given to the customer confirms your advice in the clearest way

Follow these standards

APERs within Legal & General and your firm have a regulatory responsibility to ensure that you follow these standards. You must always encourage your customers to review all of their protection needs. Where no specific ruling or guidance exists within these standards, we expect that an individual or firm will take an intelligent view, and one that is in the interest of the customer, and not seek to exploit any apparent omissions. If you have any queries regarding these standards, contact the Network Business Support Team by email on [email protected], or call 0845 070 1303 Option 1. The POS Library will hold the most important documents you require to complete your duties. In addition to this document, you should also refer to The Process Guide for descriptions on specific processes (e.g. pricematch, attaching a document) and POS Technical Guide for in-depth descriptions on how to use your POS system in the most efficient way.

mailto:Network%20Business%20Support%20Team



GENERAL PROCESS - FUNDAMENTALS

In order to start advising and selling compliantly, you must have been granted the appropriate licence(s) and been trained according to the standards detailed in the Legal & General Network’s Performance Management Adviser Scheme (or LGFS equivalent).

You must follow the guidance in our ‘What good looks like’ sales processes in order to closely align yourself to our expectations. Telephone based sales teams are subject to additional requirements detailed in the table here.

You must provide your customer with a valid IDD/CIDD/PSDD (hereafter known as disclosure document) on first contact when you anticipate making a personal recommendation on a protection policy. You must attach this disclosure document to the customers POS record.

The Network does not permit protection business to be carried out on a non-advised or execution only basis. The only product currently available on this basis is the over 50’s plan.

Any exceptions to this will be formally communicated to you, and will require separate training and licencing.

You must fully explain each section of the disclosure document so that the customer is fully aware:

Who the FCA are and how they oversee us and protect them as a customer Who you work for/with and how that firm links with the Network (especially where your brand is a trading

style of the AR) The scope of service you and your firm can offer (therefore introducing your and Legal & General’s brand) That you’ll be giving advice and making a recommendation to them The complaints process and protection available to them via the Financial Ombudsman and Financial

Services Compensation Scheme

The latest disclosure documents are always available from the POS library. The expected sales process for face to face sellers is documented in Appendix 8.0 The expected sales process for telephone sellers is available in Appendix 8.1, with a table of requirements

below

GENERAL PROCESS - EXCEPTIONS

A protection only disclosure document must be used if you’re only giving protection advice, or giving protection advice alongside a non-regulated mortgage.

http://documentlibrary.legalandgeneral.com/litlibrary/lglibrary_52472.html

http://documentlibrary.legalandgeneral.com/litlibrary/lglibrary_52472.html

http://landscape/business-areas/distribution/bbsd/regulated-sales-staff-performance-management/adviser/index.html

http://documentlibrary.legalandgeneral.com/litlibrary/lglibrary_52472.html?req=internal



Telephone Sales Requirements General requirements on each call to the customer: All calls must be carried out in a way that is clear, fair and not misleading You must inform the customer they can end a call at any time and accept this gracefully should it occur or if they refuse

another appointment You mustn’t call at an unsocial hour (before 9am or after 9pm Monday to Saturday and on Sundays or Bank Holidays) or on an unlisted telephone number unless this has been agreed in advance with the customer You must give the customer an idea of the length of time the call will take If calls are recorded, you must inform the customer of this as early in the call as is feasible and reasonable to do so

Stage Requirement

Initial (non face to face) Verbal Disclosure

Provide customer with:

Your name, firm name and (unless the call is initiated by the customer) the commercial purpose of the call and the length of time the call is likely to take

Your scope of service (i.e. the protection products you’re authorised to advise on)

That the firm will provide an advice based service

That this information (in the form of a disclosure document) will be confirmed in writing within three business days

Information that the contract between you (the firm) and your customer may be cancelled at any time

That the disclosure process described above is limited, that other information may be available on request

In order to proceed with the appointment based on this limited information, the customer will have to give their explicit consent. If the customer doesn’t want to proceed on the basis of limited disclosure, then you must send them written details of the cover they’re interested in and arrange a further telephone call to discuss this.

Once you have decided upon your recommendation, you should disclose the following to the customer prior to conclusion

The following disclosure must be made each time a recommendation is made and for each product recommended (see section 3.3 and Annex A for full details):

Policy description and cover provided

Significant features and benefits

Significant or unusual exclusions or limitations

The total price over the term to be paid for each policy

Notice of the possibility that other taxes or costs may exist in respect of the insurance contract that aren’t payable via the firm or imposed by it

The cancellation periods and the conditions for exercising the right to cancel and any information about what the customer may have to pay

A telephone number or address to which a claim may be notified

If the customer doesn’t want to proceed on the basis of limited disclosure, then you must send them written details of the cover they’re interested in and arrange a further telephone call to discuss this. If a referral is required to a third party provider (and if this is allowable under our current standards), then you’ll need verbal consent to proceed with that referral

In writing and prior to submission to Legal & General (except where immediate cover required, see below)

You must send to the customer:

Disclosure document

The appropriate key features documentation

Statement of price/ illustration

Information about cancellation rights

If the policy is required immediately

You must provide to the customer: A verbal version of the PSL letter (including confirmation whether the contract is personally recommended and the underlying reasons for the recommendation, any resulting shortfalls etc.) Plus: All the documentation detailed in the box above in the medium that is most suitable for them to read at their earliest convenience



2.0 FACTFINDING

2.1 GATHERING ACCURATE INFORMATION

2.2 DETAILING EXISTING POLICIES

2.3 ESTABLISHING AFFORDABILITY

2.4 IDENTIFYING AIMS AND VIEWS



2.1 GATHERING ACCURATE

INFORMATION.

Seek the customer’s views on their existing policies. What are they intended for? Do they intend to keep them? If so what for? Would they want to replace them and why? All discussions should be added to your POS notes.

GATHERING INFORMATION - FUNDAMENTALS

When introducing the fact find, you must stress to the customer the importance of receiving full, honest and accurate answers to the questions you ask them. Equally you should ensure that you ask for the information required by questioning in a way designed to encourage the customer to give you all the information you require honestly and accurately.

If you’re advising more than one customer, you must speak to each one to gather the information you require, or at least speak to both customers to confirm the accuracy of the information that has been provided, otherwise your advice might be unsuitable.

The fact find must be fully completed in all areas relevant to the scope of service disclosed. For example, if you’re discussing Life and CIC, you must also ensure that any mortgages held are fully documented, including term, balance, repayment type, amount outstanding and monthly payment. This will ensure you cover all of the relevant needs of the customer.

Where you’ve given a CIDD to your customer indicating that you’ll be giving mortgage and protection advice, you must ensure that you then finalise the advice process by confirming your recommendations for both mortgage and protection.

If your firm’s process is to separate the advice (e.g. one adviser deals with Protection, and another deals with Home Insurance) then the initial adviser must include a note in the PSL to explain that a second adviser will deal with another part of the advice, and what that part is.

It is mandatory that you attempt to discuss with a customer all of their protection requirements. If you’re able to have this discussion then the aims and views section (protection tab) must be accurately completed to reflect their needs, and include the impact of not protecting themselves. Your PSL must confirm these back to the customer.

Where your customer has existing single life policies with Legal & General, you should consider recommending that they are written in trust.



2.2 DETAILING EXISTING POLICIES.

DETAILING EXISTING POLICIES - FUNDAMENTALS

Any existing policies, employer benefits (including sick pay or death in service), or provisions that might be used to cover an event (savings etc.) must be recorded in your POS record in order to get a full picture of the customer’s circumstances.

Additionally:

FULL details of the customer’s sick pay and redundancy benefits must be received and recorded in the POS record PRIOR to making a recommendation to protect income (e.g. ASU & IPB).

Care must be taken to record and take into account any future increases in employer benefits (e.g. stepped increase due to length of service)

Best endeavours must be made to obtain the sick pay and redundancy benefits – if not received then you must record in the PSL that they have not been received

You must endeavour to gain all of the following details of customer’s existing policies and employer benefits including:

Life/lives assured and how the policies are written

Type of cover

Current sum assured/benefit payable (e.g. waiver, guaranteed insurability options etc.)

Start and End date of the policy

Monthly cost of each policy, which should also be included in the budget planner where these are to continue

You should request copies of a customer’s existing policy/ies (that relate to your scope of service) in order that you can get accurate details, and therefore give a suitable recommendation.

We would not expect you to get details of, or include within your advice, any product outside of your scope of service (e.g. whole of life policies if you’re a Mortgage and/or protection adviser). However, where a customer declines your recommendation for protection because such policies exist, then basic details must be recorded in the POS record. We would expect you to get details of repayment vehicles for mortgages, but do not expect you to give advice on them.

You will be able to get details of all current Legal & General policies (by contacting New Business department) provided that the customers give their written authority to enable you to do so.

If you can’t get sufficient details of 3rd

party policies then you can’t advise on, or include them in your recommendation. This must also be recorded in the PSL.

You should decide whether using flexibility options or Guaranteed Insurability Options result in a better outcome for the customer than a replacement policy. You should note in your POS record the reasons for or against using these options, including the difference in cost and/or benefits.

DETAILING EXISTING POLICIES - EXCEPTIONS

If you are arranging an interest only mortgage, it is imperative that you get details of the customers intended repayment strategy in order that the lender can assess them.



2.3 ESTABLISHING AFFORDABILITY

ESTABLISHING AFFORDABILITY - FUNDAMENTALS

Any figures given in the budget section must be realistic (if you’re giving advice on mortgages and protection, then this can be checked within the bank statements required to advise on the mortgage). You must fully complete the budget planner (including all expenditure) in order that you can accurately advise the customer on their needs and protection requirements.

Where you have given mortgage advice, the budget section of the fact find must be fully completed in line with the requirements of the Mortgage Advice Standards.

The customer must have sufficient available funds to be able to afford your recommendation.

If you’re advising on:

Protection only (e.g. not linked to any new mortgage event) = Available funds must be determined from current income and expenditure.

Mortgage & Protection (or protection to cover a mortgage event) = Future mortgage payment must be included and consideration given to any increase in bills. This should be added to current expenditure to determine available funds.

Where a customer can’t afford to protect all needs identified due to insufficient available funds you must:

Prioritise customer needs (ensuring that the best customer outcome is the agreed priority)

Identify through discussion with the customer whether they’d prefer:

No cover in one or more areas, or

Reduced cover in one or more areas

Record full details of these discussions (including total cost of the original quote to fully protect customer) in your fact find notes and reconfirm them in the PSL, including all uncovered areas in the shortfall section

You must not recommend cover that isn’t affordable.

ESTABLISHING AFFORDABILITY - EXCEPTIONS

A full budget section must be completed in all instances EXCEPT if Buildings and/or Contents insurance is the only protection being discussed with the customer. Just a summary of income and outgoings documented in the expenditure section is acceptable in these cases.



2.4 IDENTIFYING AIMS AND VIEWS

IDENTIFYING AIMS AND VIEWS - FUNDAMENTALS

You must accurately complete the Aims and Views section, under the protection tab in the POS system by gathering the customers views on protecting themselves or their family against the financial impact caused by:

Death

Critical Illness

Accident and sickness

Redundancy or Unemployment

Damage to property and contents

You should take care to ensure that your conversation takes into account what the customer would want to happen in the event of a claim. For example, what would they do with money paid from a critical illness claim? Would they want to repay the mortgage, or would it be used for treatment or another purpose?

Depending on the answers given by the customer in respect of the above, you must follow the table below appropriately in order for your POS record to be accurate.

You must discuss with the customer, and indicate in the aims and views, whether they have any preference for Guaranteed or Reviewable premiums.



Aims and Views Completion Guide - You should read this guide before completing the Aims and Views pages to

ensure that you can successfully follow the requirements in the table below. It is mandatory to encourage your customers to review all of their protection needs. To fully understand the requirements of this section, please see the Annex C for a screenshot.

Radio Buttons

Yes - Customer must have provisions or policies to meet the potential need (where these are to continue) and therefore evidence will need to exist No - A need exists and a discussion should occur in order that you find a solution to meet that need Not Applicable - No need in that area – e.g. protection for mortgage but no mortgage exists, or not in the scope of service disclosed to the customer

‘Impact’ Boxes

Impact on you – Summary of your specific discussions on the impact on a customer Impact on family – Summary of financial implications, or impact on family to be included here

‘How do you want to address’ boxes

‘How do you want to address this?’ box – Answers should be:

Customer/s want a quote

Customer/s don’t want to address and area/s not being addressed (plus customers name if other party wants to

proceed to quote and recommend)

Customer/s don’t want to discuss and which area/s not discussed (plus customers name if other party does want to

discuss further) If not reviewing now box – must include any reason given for not wishing to address and the reason must be included in the PSL

Aims and Views requirements

No protection discussion required

We expect How to document correctly

Customer does not want to enter into discussions on any areas of protection (Note – it is mandatory to offer protection advice to all customers)

All areas of the protection fields left blank or untouched

Add note to POS record to state that customer did not wish to discuss. Letter 1 must be personalised, sent to the customer and copy added to the POS record

Customer does not want to enter into discussions on one or more areas of protection

Notes in the impact box to explain which area of cover they did not wish to discuss. Summary of answers in relation to impacts where there was a need

Issue PSL detailing recommendations in the areas that were discussed, and include the areas not discussed, along with resulting shortfalls

Generic protection discussion takes place, but customer doesn’t want to take any further

We expect How to document

Customer does not want to progress a protection discussion further, regardless of the cost of the product

How do you want to address box to state ‘did not wish to address’ and the name of the area that has not been addressed. Warning – if you quote (after finalising fact-find), then we will consider that you have had sufficient discussion to make a recommendation

Statement in PSL shortfalls area to detail the areas that the customer did not want to address and the reasons. If customer doesn’t want to address any area of protection, then adapt Letter 1 to

read that although discussions took place, no quotations were given

Specific protection discussion takes place, and customer receives personalised illustration(s)

We expect How to document

Customer wants to see personalised cost of product(s) you’ve discussed, therefore indicating they agree with the need for protection

A full recommendation for the product discussed

As per Recommending & Record Keeping sections

Following Recommendation We expect How to document

Customer fails to give a decision following your recommendations being made to them

Fully completed aims and views and impact boxes as above section

Issue letter 2 and add to binder prior to

exchange if mortgage related, and within a 31 day period for other protection needs



3.0 RECOMMENDING.

SECTION DESCRIPTION

3.7.1 PROTECTING A MORTGAGE OR OTHER LOAN

3.7.2 PROTECTING AN INCOME

3.7.3 PROTECTING A FAMILY OR THE LIFESTYLE OF THE CUSTOMER

3.7.4 PROTECTING PROPERTY AND CONTENTS

3.7.5 OTHER PROTECTION PRODUCTS

3.7.6 TRUSTS

3.2 ESTABLISHING POLICY SUITABILITY

3.3 PRIOR TO RECOMMENDING

3.4 AFFORDABLE RECOMMENDATIONS

3.5 ADVISING ON EXISTING POLICIES (RETAINING OR CANCELLING)

3.1 GENERAL RULES OF RECOMMENDING

3.7 WHAT TO RECOMMEND

3.6 ADVISING ON EXISTING POLICIES (CIC CANCELLATIONS)



3.1 GENERAL RULES OF

RECOMMENDATION

GENERAL RULES OF RECOMMENDATION - FUNDAMENTALS

Your recommendation must result in the right outcome for the customer. Your POS record and PSL must contain adequate information in order for Legal & General, The Sales Quality Team, or Regulatory bodies (e.g. FCA, FOS) to understand the reason why your recommendation was suitable and how it met the needs of the customer/s.

You must have verbally disclosed all the relevant parts of the ‘What customer needs to know at recommendation stage’ section of the Mandatory Product Disclosure Guidance (Section 3.3 and Annex A), prior to finalising your recommendation.

The right outcome for your customer is unlikely to be based upon a formulaic approach (e.g. 4x income). Every customer and their needs are likely to be different and your recommendations and documentation should reflect this.

The Network does not permit protection business to be carried out on a non-advised or execution only basis. The only product currently available on this basis is the over 50’s plan. Any exceptions to this will be formally communicated to you, and will require separate training and licencing.

Prior to agreeing to fund a policy on behalf of a customer for any period of time (including from proceeds of commission receivable) you MUST obtain permission from the Business Support Team by email on [email protected].

mailto:[email protected]



3.2 ESTABLISHING POLICY SUITABILITY.

ESTABLISHING POLICY SUITABILITY - FUNDAMENTALS

Prior to making a recommendation, you must ensure that any policy/ies (or combination of policies) you are considering recommending:

Are suitable for the customer, and

Are affordable to the customer, and

The customer is eligible to apply, and

Have a reasonable chance of claiming, and are aware of when limitations may occur, and

Result in the right outcome by covering the identified needs of the customer

FCA rules require you to recommend a policy that is suitable and meets the demands and needs of the customer. To do this you must gather sufficient information from the customer, and fully explain the product to them * see Section 3.3. and Annex A.

It isn’t sufficient just to inform the customer of the product features and limitations and then allow them to make a decision. You must ensure that you recommend the right products, having obtained the right information.

Various occupation types (including Armed Forces), employment statuses (including self-employed) and residency statuses may not be eligible for certain types of cover, or be able to claim in certain circumstances. You must confirm that the customer is eligible to take out or claim on a policy PRIOR to recommending it * see Annex A and Annex B

You must assess and discuss with your customer whether their current circumstances or potential future circumstances allow them to take out or may affect their chances of claiming on a policy PRIOR to recommending * Annex A and examples below

If customers are eligible for cover under a policy, but may not be able to claim in certain circumstances and still want to proceed, you must provide an explanation of these circumstances AND the reason why cover is still considered suitable in the PSL

You must always give the customer the latest Key Features Documentation, a statement of price and any necessary supporting documentation to support your recommendation, (and for any the customer wishes to proceed with) in writing, prior to submission of an application(s) to Legal & General. You can check the AR Centre for the latest documentation.

When discussing the key features of a policy, you must establish whether the customer has an interest or need to explore an option or feature further. These discussions will help in your decision whether to recommend these additional options

Discussions that result in policy/ies being recommended despite exclusions being applied must also be summarised in the POS record and PSL letter.

Discussions that result in no recommendation being made due to any product being unsuitable must be summarised in the POS record and PSL letter.



Examples:

1) Customer is regularly off work with a pre-existing condition. As pre-existing conditions are not covered for the first 12 months

(provided no treatment received), you may conclude that the likely reason to claim is excluded and therefore the policy isn’t suitable. However, the customer may still wish to proceed given the other cover the policy can offer despite the exclusion (for other illnesses not linked or for after the initial 12 month treatment exclusion). It must be clear in the PSL how this decision came about and why.

2) It must be clear the amount that the policy will pay out and when, and if any external factors may affect it – e.g. stepped benefits levels on IPB and that its benefit amount in claim may be reduced due to certain state benefits, continuing income from a business etc.

3) Any restrictions on cover offered to foreign nationals or workers temporarily living abroad must be fully disclosed – see Annex B

ESTABLISHING POLICY SUITABILITY - FUNDAMENTALS (cont.)

ASU specific Fundamentals:

When discussing unemployment cover with a self-employed customer, you must establish that they satisfy the criteria of ‘self-employed’ as set out in the policy document. Additionally, your POS record should be clear as to the type of self-employment (e.g. sole trader, partnership etc.). To simply state self-employed will be considered insufficient. (Note: A director will be classed as employed for unemployment cover if they have a shareholding of more than 25%).

You must always consider the customer’s potential entitlement to redundancy pay from their employer prior to making a recommendation for unemployment cover. For example, if they have worked for a large established company for a long time and they believe the company is unlikely to cease trading, they may not feel there’s a need for cover if their redundancy package is generous. However, you must discuss with the customer the risk that any company can cease trading or re-structure and the resulting discussion should help you form a view as to whether there is a need. It’s important that you document in the POS record any such discussions

When recommending unemployment cover to a customer switching from a third party provider ASU contract to Legal & General ASU cover, Switcher cover is not available unless:

The customers current cover has been in force for more than 12 months continuously

There have been no claims within the last 12 months

The customer intends to cancel their current policy once ‘switched’

In order to claim on , Self-employed Sole traders will have to satisfy the ‘cease to trade’ criteria. This means that customers will have to totally cease their business on a permanent basis because the business has insufficient assets to meet its debts and liabilities, and: They will have to prepare and submit their final closing accounts to HMRC, or Their business will have to be placed in the hands of an insolvency practitioner or an officer of the

bankruptcy court, or Their partnership will have to be dissolved and they will have to prepare and submit their final closing

accounts to HMRC In order to claim, your customer may need to provide proof that the business has ceased to trade, accounts, tax returns and bank statements plus any bankruptcy orders or IVA agreements where applicable. A claim will only be paid if they do not trade at all.

For Sole traders and Unlimited Liability Partnerships, the claims criteria for Unemployment cover is more restrictive because these customers must enter into an IVA or personal bankruptcy to make an unemployment claim, both of which may encourage and see customers continue to trade. In this instance the customer will not be able to make a claim, therefore it’s highly unlikely you’ll recommend this cover to this segment of the market. Any recommendations to this segment of the market must be pre-approved by Business Support Team.



3.3 PRIOR TO RECOMMENDING.

Note –

Insurance companies can refuse to pay claims if the information provided by a customer in answer to the insurance companies’ questions amounts to a deliberate or reckless misrepresentation of the facts. Where the answers provided by the customer amount to a careless misrepresentation of the facts then the insurance company may be entitled to refuse the claim or claim another remedy, such as a reduction in the amount of the claim. The nature and extent of the remedy available will depend on the circumstances of every case and will be based on what the insurer would have done differently, had the customer taken care to answer the questions accurately. If a misrepresentation is made honestly and reasonably by the customer then the insurer will have to pay the claim.

PRIOR TO RECOMMENDING - FUNDAMENTALS

You must ensure that the customer is physically on UK soil at the time of advice and all correspondence from Legal & General must be issued to a credible UK postal address

You must discuss with each customer which, if any, of the additional options, features and benefits on Legal & General policies will benefit their situation. To achieve this you’ll need to:

Establish which needs exist (see Section 2.4 – Identifying Customer Aims and Views)

For the products you’re likely to recommend to meet these needs, use the product key features documents to describe the additional options and features

Discuss the importance of each of these options and features, and establish whether there is a need

Decide between you which of the features that you feel will best meet their needs and requirements, and include these within your recommendation

Once you have assessed that a policy is suitable for a customer, and that they are eligible, you must verbally disclose all the information in the Mandatory Product Disclosure Guidance (see Annex A). This is so that customers can make an informed decision whether to proceed. This disclosure includes, but isn’t limited to:

The policy benefits, limitations and exclusions. You must also explain customer specific exclusions e.g. those that may apply due to pre-existing medical conditions, nationality etc.

The duration and monthly cost, and whether the premium is guaranteed or reviewable. If reviewable, when the policy will be reviewed

The total cost over the full term of the policy

Their cancellation rights – this will either be 14 or 30 days depending on the product

At the chosen stage, explain that the full terms and conditions of any policy will be sent to them and they should read these carefully

An explanation that insurance companies can share information and may be entitled to refuse a claim if the information that a customer provides in answer to the insurance companies questions is incorrect and amounts to a deliberate, reckless or careless misrepresentation of the facts



3.4 AFFORDABLE RECOMMENDATIONS.

AFFORDABLE RECOMMENDATIONS - FUNDAMENTALS

You must not recommend cover that’s not affordable. You must recommend according to the available monthly funds of the customer (as detailed in the budget section of the POS record), and not the customers view on what they say is affordable or what they want to spend. The budget section must be a clear indication of available funds.

If the cover you recommend has to be reduced or removed altogether due to affordability, then the resulting shortfalls must be documented in the PSL.

Post application affordability issues may be caused by:

Rated cover

Customer led changes to the policy terms or sums assured You will need to review your recommendation to ensure it is still affordable. You must confirm in your POS notes that you have checked this. If your recommendation needs to change then you must confirm any changes in writing by re-issuing your PSL



3.5 ADVISING ON EXISTING POLICIES

(RETAINING OR CANCELLING)

ADVISING ON EXISTING POLICIES (RETAINING OR CANCELLING) - FUNDAMENTALS

You must encourage the customer to review all areas of protection, and ensure your advice covers your full scope of service, not just a review of the customer’s existing policies.

If sufficient existing policy details have been received, you must make a recommendation to the customer as to whether they should retain or cancel each policy. It’s not acceptable to sell a new policy and leave it for the customer to decide to whether to cancel or retain. You must ensure that you have fully compared policy benefits between existing and proposed prior to deciding whether to recommend cancellation. If the existing policy fully covers a current customer need, you would normally recommend retention.

It is likely that you would recommend retaining if: The customer has a current need for that cover OR Aims and Views discussions identify a need for family protection and the term and amount remain

suitable to those needs OR You’ve identified during your discussion that illnesses/ definitions included in a current CIC policy are

more suitable to their needs e.g. cover for angioplasty Other benefits on the policy better meet the customer’s needs If age and current health will inhibit the customer in taking a new policy If the existing policy does not fit the need better than a new policy, then cancelling may be suitable.

If you’re recommending cancellation, your customer mustn’t cancel the existing policy until any new policy is on risk

You must discuss what the customer values about the benefits within their existing policy e.g. illnesses, definitions, benefits. These discussions will help to establish if the current Legal & General policy will provide enhanced cover or benefits for the customer

You must establish if the customer will be subject to any costs because of the cancellation, e.g. a deferred mortgage fee that may be invoked, or the ability to claim a mid-term refund of a general insurance premium

ADVISING ON EXISTING POLICIES (RETAINING OR CANCELLING) - EXCEPTIONS

If you’re only giving advice to one party (e.g. due to a divorce) then no recommendation to cancel or retain can be made without speaking to both parties. If this is the case then you must include a statement in the Existing Policy Supplement that you have been unable to advise both parties and have not taken the policy into account when giving advice



Example

The new policy may not pay out if the customer doesn’t fully, honestly and accurately answer the questions asked of them by you/us. You must explain this early in your conversations as it may affect their decision to replace the policy. Where the customer does not wish to proceed with replacing a policy, having previously stated a potential need/wish to do so, then this fact must be documented to confirm that it was the customer’s choice not to proceed, and the reason why, if known. In order to compare previous CIC policies definitions, see the AR centre – Our Products > Protection > Critical Illness Cover > Key Documents > CIC Definition History

ADVISING ON EXISTING POLICIES (RETAINING OR CANCELLING) - FUNDAMENTALS (CONT)

Prior to replacing an existing protection or general insurance policy, you must ensure that the customers are aware that they must answer all questions requesting information on medical consultations, conditions and treatment they have received since applying for their existing policy honestly and accurately and you must tell them about the implications if they don’t.

* See example below

You must not rebroke a policy unless it is in the best interests of the customer (not the adviser). Cost

should not be the principle reason for replacing cover. Other reasons must be fully explained in the PSL

If the customer seemingly has sufficient existing cover, employee benefits or provisions then any recommendation for additional cover in these areas must be fully explained in the PSL

If the existing policy is a TELIP (tax efficient life insurance policy) you must point out to the customer that it has tax relief that can’t be transferred to a new policy and you must record this in the PSL

Prior to switching to Legal & General ASU cover from any other ASU product, you must establish whether there are any situations that would result in the customer being unable to claim, e.g. whether a medical condition has arisen since taking the original policy that would render the customer unable to claim as this might be classed as a pre-existing condition on the new ASU policy. Additionally, where you’re switching from a policy with Unemployment cover, you must make the customer aware that if a claim occurs within the first 60 days of the policy, only the benefit amount from the original policy will be paid. You must ensure that you record all such discussions in your POS notes

Any changes to the health of the customer since the previous sale may result in loadings or exclusions due to underwriting decisions and this may affect recommendation

ADVISING ON EXISTING POLICIES (IF CONSIDERING CANCELLATION) - EXCEPTIONS

If a new policy covers customer needs more suitably than the terms of their old policy, any loss of cover from their old policy must be discussed fully with the customer and documented in the PSL



3.6 ADVISING ON EXISTING POLICIES

(CIC CANCELLATIONS).

See the Sales Process Guide in the POS Library for the CIC Cancellation Requirements.

ADVISING ON EXISTING POLICIES - FUNDAMENTALS

You should only recommend the cancellation of a CIC policy if, when comparing to the new cover, the customer is unconcerned that they might lose a particular illness (or alter their ability to claim) in comparison to their current cover. Conversely, retention may only be suitable if the existing policy terms are superior to that of the policies currently available through Legal & General.

If you can’t access a customer’s existing 3

rd party policy documents, then you must make it clear that you

haven’t taken them into account during your recommendation, and confirm this in the PSL existing policy supplement

ADVISING ON EXISTING POLICIES - EXCEPTIONS

Where a type of cover or benefit is lost, or the ability to claim is affected because the cover gained from a replacement policy results in a more suitable policy overall, then any such loss of cover or benefit, or loss of ability to claim must be fully discussed and agreed with the customer before proceeding, and this must be documented in the PSL



3.7.1 WHAT TO RECOMMEND

(PROTECTING A MORTGAGE OR OTHER

LOAN)

PROTECTING A MORTGAGE OR OTHER LOAN - FUNDAMENTALS

You must recommend that the customer fully protects the mortgage. Taking into account any continuing existing cover, employee benefits, or any other provisions/resources used to reduce the cover required, the amount of cover recommended should be: Life cover equal to the full amount of the mortgage (inc fees) for the whole of the mortgage term MDTA must be recommended for a repayment mortgage MTA must be recommended for an interest only mortgage A joint life policy must be recommended to cover a joint mortgage On all of the above, Critical Illness cover as appropriate to the need Alternatives to this could result in a suitable outcome, but where they are recommended, then your PSL would be required to fully explain why (cost may not be considered the sole reason)

You should assess the need to protect any BTL properties and any other liabilities directly linked to property ownership (e.g. Government shared equity amount). Your recommendation should be for the amount and the term of the sums owed.

You must recommend the additional options that would be of benefit to your customer (where these are agreed during your discussions - these can be established during your verbal disclosure). Your PSL will need to explain why each additional option recommended will be of benefit to them. Although waiver is currently a standard inclusion, options such as TPD can be added at an additional cost, and your customer must be aware of the additional cost (you will need to confirm that they are aware in the PSL)

If referring a customer to a secured/unsecured loan provider: If you establish that the customer has a protection shortfall prior to the loan commencing, then you must make the recommendation immediately. Additionally they’ll have a need to cover the loan being arranged once it commences. If you’re recommending a decreasing term assurance policy to protect a secured loan, you should confirm in the PSL that the policy assumes an interest rate of 9% or less. As secured loan rates are typically higher than for a regulated mortgage, and the rate exceeds 9% then you should discuss and consider whether a level term assurance would be more suitable

We would not normally expect a recommendation for term assurance alongside any lifetime mortgage that becomes repayable upon death. You must be licenced to sell whole of life policies in order to make a suitable recommendation in this situation.

Recommendations for protecting lifetime mortgages will require a business case to be approved by Business Support and Quality prior to making a recommendation. This business case will be required to provide detailed reasoning for the amount and term of the cover. An application must not proceed until we provide you with a decision

Shared equity loans may be better covered by a separate MTA policy for the amount and term of the equity loan. Where no term for the equity exists, then link it to the term of the mortgage




PROTECTING A MORTGAGE OR OTHER LOAN - EXCEPTIONS

For shared ownership mortgages it would be more suitable to recommend an MTA (and CIC if applicable) for the maximum share that can be purchased, less any deposit being provided by the customer. The mortgage can then be repaid and any surplus can be used to fund rental payments or buy some or all of the remaining share (also refer to Section 3.7.2)

Single policies may be more suitable but only when:

Age restrictions on a policy stop you from recommending the full term to both customers

Where customers are arranging their mortgage as tenants in common

Customers consider that their future needs may be better served by single policies (for example, where flexibility may not exist)




(PROTECTING AN INCOME)

PROTECTING AN INCOME - FUNDAMENTALS

You must firstly discuss the income that will be required in the event of long-term sickness or unemployment. Taking into account continuing existing cover, employee benefits, or any other provisions or resources to be used to reduce the cover required, the cover recommended should then be: IPB or a combination of IPB/AS to cover a period of sickness, ideally until the customer intends to retire,

covering the need in the most effective way, for the amount of income required to cover their need To utilise stepped benefits for any period where payment is received from employers, continuing income

from a business or existing/new ASU/IPB policies Cover for unemployment

Care must be taken where any combination of employers benefits, AS or IPB result in a period where the customer receives no/reduced policy benefits in claim. Where these occurrences aren’t fully explained to the customer and documented fully, they could form the basis of a legitimate complaint. Prior to making your recommendation you must decide the most effective and suitable solution to cover the need. This will be established in discussion with the customer and considering the following: What deferred period is most suitable What product or combination of products/options best meets the customer’s needs (cost isn’t necessarily

the measure of this) Whether the customer can fund a period of sickness themselves? Is BTDO cover on ASU more suitable than standard cover Is it acceptable for a customer to pay for a policy they may not be able to claim on, or where the benefit

may be reduced, or not paid at all

Where a customer could receive benefits beyond 12 months from employers, a group PHI scheme or ASU benefit, AND would still like to have IPB cover (for the long term benefit it provides) despite there being a period where they may receive reduced or no benefits, you must: Discuss and gain agreement that the customer understands that for ‘X’ period, reduced or no policy

benefits will be paid on claim Discuss and gain agreement that the customer understands that they may be paying a premium for a

policy that will pay out after ‘X’ period of sickness Notify Business Support of the POS record reference number

You must recommend the additional options that would be of benefit to your customer (where these are agreed during your discussions - these can be established during your verbal disclosure). Your PSL will need to explain why each additional option recommended will be of benefit to them. Although waiver is currently a standard inclusion, options such as PTI and Indexation can be added at an additional cost, and your customer must be aware of the additional cost (you will need to confirm that they are aware in the PSL)

If recommending maximum cover under IPB, you will need to discuss and decide whether the customer wants to adjust that cover downwards due to the possibility that they may receive some state benefits related to their sickness (e.g. ESA), and this would affect the IPB benefit received in claim (if the benefit then means total income exceeds the maximum benefit receivable). Conversely, you will need to discuss the possibility that there may be a shortfall of cover if they are not awarded such benefits. You must document such discussions in the PSL

Housepersons (IPB only) - Upon identifying a need, and if affordable, you should have a discussion to establish what benefit is required to financially support your customers in the event of an accident or sickness (subject to policy limits), and recommend accordingly.



Recommendation notes: When considering the amount of cover, each customer’s situation may be different and should be treated as such, for example if they have:

High outgoings but low earnings – they might need cover for the maximum available, or

Low outgoings but high earnings – they might only need cover for their outgoings

PROTECTING AN INCOME - FUNDAMENTALS (CONT)

Customers on maternity leave (IPB only) - the maximum that can be recommended is £1667pm. If the customer is intending on returning to work then 60% of gross pre-maternity income should be recommended (e.g. pre-maternity income of £1000, recommendation should be for £600) although this should be reviewed on their return to ensure sufficient cover is available. If they do not intend to return to work, then recommendation should be as per Housepersons above

If recommending ASU, AS or U cover to a customer on maternity leave, you must ensure they intend to return to work otherwise the policy will not be suitable for their needs. You must point out to the customer that they must have returned to work in order to be eligible to claim on the policy

LIFESTYLE COVER

AS, ASU or U recommendations linked to a ‘Mortgage Sale’ * cannot be accepted/partially accepted/chosen/applied for until the LATER of:

The 8th

day after the mortgage offer is received by the customer (this date must be noted in your POS record

The 8th

day after you have given them a personalised illustration detailing your recommendation This period prohibits you from selling Lifestyle cover as it is designed to allow the customer to make an informed decision about whether to proceed with your policy recommendation. Two additional days must be added to the time periods above if illustration is posted (so replace 8

th day with

10th

day in two bullets above). Or: The policy can be applied for but the customers must have requested to proceed by getting in contact

with you (minimum of 24 hours after receiving their illustration) by phoning or putting in writing to you their intention to proceed without utilising the full prohibition seven day period. This exception process can be initiated by the customer at any point in the ‘Mortgage sale’ * period but CANNOT be prompted by you in any way.

On the 8th

day after giving the personalised illustration (or 10th

day if posting), you may contact the customer to further discuss your recommendation for AS, ASU or U and their intentions. Prior to applying for the policy, you must: Re-confirm that you give advice and a recommendation as per your disclosure document so the customer

fully understands that you have made a personal recommendation Re-disclose all ASU policy characteristics, features, benefits, limitations and exclusions as per the

Mandatory Product Disclosure Guidance – see Section 3.3 and Annex A.

To receive a Lifestyle cover illustration for a customer where the recommendation is to cover over £2999 pm, you must request this via the Giology quote system. A personalised illustration will then be sent by email to you. Further details may be required by GI Department including proof of income

You must not only recommend joint ASU policies as they can inhibit the customers in achieving their desired level of cover. Single ASU policies will allow each party the flexibility to review their own cover.



‘Mortgage Sale’

‘Mortgage Sale’ means any mortgage activity occurring within seven days of an initial customer meeting or within 30 days following the issue of a mortgage offer. Mortgage activity is defined as being you, or a firm linked to you (including any introducer/lender) applying for a mortgage (regulated or non-regulated). Outside of these periods, no prohibition of the sale of ASU applies. If you have arranged the mortgage, then a copy of the offer must be included in the binder, or if the mortgage was introduced to you, then the date of the offer in the notes.




(PROTECTING A FAMILY OR THE LIFESTYLE

OF A CUSTOMER)

PROTECTING A FAMILY OR A LIFESTYLE - FUNDAMENTALS

You must recommend protecting the customer or their family in the event of death or critical illness. Taking into account continuing existing cover, employee benefits, or any other provisions or resources to be used to reduce the cover required, the cover recommended should then be:

To protect a family - Life cover and/or Critical Illness cover providing a monthly benefit in the event of death, sufficient to cover the need, for the term required

To protect a Lifestyle need - Life cover and/or Critical illness cover to provide a lump sum or monthly benefit, sufficient to cover the need, for the term required

You will therefore need to establish the amount of cover required with your customer, and that discussion is likely to be focused on providing sufficient cover to replace a salary, covering the outgoings of the household, adapting the home to a change in circumstances, or the cost of replacing the essential duties of an individual. The required term is likely to provide cover until the youngest dependant will be self-sufficient or until all dependants cease to be financially reliant on the customer. Formulaic approaches are unlikely to result in the best customer outcome. A summary of this discussion and the reason for the amount and the term must be documented in the PSL. If the selected term is not available in the POS record select ‘Long Term’, and add notes

You must not sell (or allow a customer to choose) any lump sum protection product (to cover funeral expenses or to leave a lump sum to family) in the event of their death. You cannot establish when the event will occur and therefore the overall outcome would be unsuitable.

These events can only be covered by a whole of life product or convertible term assurance and therefore can only be sold if you are currently qualified by Legal & General to do so. However, even if you are qualified, Term assurance will still not considered suitable as the Network do not allow execution only sales for these types of product.

You must recommend the additional options that would be of benefit to your customer (where these are agreed during your discussions - these can be established during your verbal disclosure). Your PSL will need to explain why each additional option recommended will be of benefit to them. Although waiver is currently a standard inclusion, options such as TPD and Indexation can be added at an additional cost, and your customer must be aware of the additional cost (you will need to confirm that they are aware in the PSL)

Where relevant, the following factors should be taken into account when establishing the amount of cover required:

Existing savings and investments

Costs that may cease during the term of the cover e.g. mortgage

Other income streams that may commence during the term e.g. widow’s pensions, retirement income

The customers aspirations for their future lifestyle

The age and the needs of dependants

PROTECTING A FAMILY OR A LIFESTYLE - EXCEPTIONS

Protecting a family against the impact of death is likely to be best covered by a monthly benefit life cover. Any alternative recommendation must be fully explained in the PSL

If policy terms dictate (e.g. term less than 5 years, and therefore FPIP cannot be sold) then a lump sum policy would be allowable

Where a defined need would best be served by a lump sum (e.g. payment of university fees) then this may be considered suitable




(PROTECTING PROPERTY AND CONTENTS)

PROTECTING PROPERTY AND CONTENTS - FUNDAMENTALS

If you identify a need to protect a property (whether residential or buy to let) and/or its contents, you must make a suitable recommendation for either home insurance or landlords insurance.

You must recommend the additional options on the policy (such as accidental damage) that, during your discussions, you believe would benefit your customer (this can be established prior to verbal disclosure). Your PSL will need to explain why each additional feature recommended will benefit them.

If customers are considering paying monthly premiums for their Buildings and/or contents insurance, you must read to your customers the following script:

"If you wish you can pay your premium under a running account credit agreement, the amount you’ll have to pay each month is £x and the total cost will be £y. We are required to make you aware that should you fail to make payments when they are due we may cancel the policy and use any premium refunded and any money due in relation to a claim to repay your outstanding credit. You may also have to pay any reasonable charges, legal costs and expenses that we may incur and we (Legal & General) may take legal proceedings to recover any outstanding credit due. Missing payments could also make credit more difficult to obtain in the future. Are you happy to pay for this policy by monthly direct debit?"




(OTHER PROTECTION PRODUCTS)

Further information and application forms are available on the AR Centre – Our Products > General Insurance > Literature > Buyers protection

OTHER PROTECTION PRODUCTS - FUNDAMENTALS

Buyer’s protection - With the exception of properties purchased under Scottish Law, there is a need for protection on all property purchases. You must always recommend buyers protection if it’s within your firm’s scope of service

If only selling Buyer’s Protection (and nothing else), then use the specific Suitability Letter stored in the POS library, and add to your POS binder




(TRUSTS)

Additional guidance on Trusts is available in the IO Library > LGN> Protection

TRUSTS - FUNDAMENTALS

You must recommend that all single life assurance policies chosen by the customer are placed in Trust. This is acceptable even when their net estate on death may be in excess of the nil rate band for inheritance tax purposes, although you must document in the PSL that they should seek specialist tax advice.

We would not expect to see a recommendation to put joint life policies in Trust as it is rarely suitable to do so

You must always leave your customer the relevant forms to complete and explain the risk of not returning the forms

Where CIC cover is included you must take care to ensure the retained benefits section of the trust form is completed so that the CIC benefits aren’t payable to the Trust beneficiaries. Also, the life assured may still be liable for the mortgage amount and ongoing payments as the beneficiaries are under no obligation to repay the mortgage

Life of another can be recommend in certain circumstances, but should not be used in preference to a trust for the following reasons: In the event of a critical illness claim the sum assured will be payable to the plan owner of the Trust and

not to the life assured. Also, the plan owner is under no obligation to repay the mortgage. If the plan owner becomes bankrupt (prior to a claim being made), then any sums payable under a claim

may form part of the bankruptcy Any monies paid in claim may form part of the plan owner’s estate for IHT purposes

Recommendations to proceed on a life of another basis will need to be fully explained and appropriate warnings will be required in the PSL to reflect the above.

You must not be named a Trustee on any policy that you arrange on behalf of a customer

TRUSTS - EXCEPTIONS

Where the primary recommendation is to provide critical illness cover to a single person and the customer is unconcerned where proceeds of the life cover will go in the event of their death, then this will need to be explained in the PSL



4.0 APPLYING.

APPLYING - FUNDAMENTALS

You must always give the customer the latest Key Features Documentation, a statement of price and any necessary supporting documentation to support your recommendation, (and for any the customer wishes to proceed with) in writing, prior to submission of an application(s) to Legal & General. You can check the ‘Our Products’ section of the AR Centre for the latest documentation.

When completing application forms you must verbally explain to the customer that they must answer all questions that we ask them honestly and accurately as any deliberate, reckless or careless misrepresentation of fact(s) may result in non- payment of a claim

You must ask all the underwriting questions fully in order that the customer can be given the opportunity to answer fully, honestly and accurately. This must be completed in all cases, whether it is a new or existing customer. Answers to all questions asked of them must include (where applicable): Details of all medical consultations, conditions and/or treatment the customer has received since applying for the existing policy must be provided, however minor the customer believes these to be. Failure to do so may mean a claim is declined and result in the policy(ies) being cancelled, and a complaint may be upheld against you if the customer can demonstrate that you have not followed these standards.

You must not assume or guess the answers to any underwriting questions.

You must ensure that you have either read to each customer, or printed and given to each customer, the OLPC declaration that is displayed on screen once full information has been gathered and before an underwriting decision is obtained or the application is submitted.



5.0 DOCUMENTING.

SECTION DESCRIPTION

5.2.1 GENERAL REQUIREMENTS

5.2.2 RECOMMENDATIONS CHECKSHEET

5.2.3 WHEN TO RE-ISSUE YOUR PSL

5.1 GENERAL RECORD KEEPING REQUIREMENTS

5.2 PROTECTION SUITABILITY LETTER



5.1 GENERAL RECORD KEEPING

REQUIREMENTS

Refer to POS Library > Training Material for guidance on how to add documents to the POS record.

GENERAL RECORD KEEPING - FUNDAMENTALS

All advice given to customers MUST be recorded on the POS system.

Your fact find and the contents of the binder must show a complete record of the information received from customers, and your documented advice to them. In addition, you should record all discussions regarding the customer’s circumstances and preferences that support your recommendation.

You must create an individually named binder on the POS system for each piece of advice given to your customers. The following must be held within that binder (where applicable): A copy of the disclosure document that was presented and explained to the customer Finalised copy of the fact find Protection illustrations that were recommended Lifestyle cover – prohibition letter Either a finalised PSL or letters of rejection (Letter 1 or 2) confirming that the customer didn’t wish to

proceed or haven’t yet confirmed acceptance of your recommendations Any PSL addendum letters Central Advice Unit referral form

Your POS record must be finalised to reflect that a recommendation has been made. For example, by ensuring that the product chosen is applied for, or by issuing Letter 1 to state that no areas of protection were discussed, or Letter 2 to reflect the customers decision not to proceed with your recommendation.

You must ensure that the status of your POS record is accurate. For example, if you’re advising two customers but have been unable to gain a decision or health details from the second person, you must ensure that your POS notes explain that the product has not yet been submitted to provider when the POS system status will say that it has.

Any paper records relating to the advice given to a customer must be: Scanned and added to the POS record, or the information from those paper records (where it is vital to

the situation of the customer or the advice given) detailed in notes Retained for the duration of the business relationship (e.g. the end of the policy) AND a further six years

beyond it Securely stored (e.g. in a locked cabinet or password protected environment), and preferably in a central

location where they are retrievable within two business days if Legal & General or our regulators require access to them.

You should never include sensitive data (such as religious or political beliefs) in your POS record or paper file. It is a breach of legislation to do so.

Self-sales of protection must firstly be referred to your supervisor or to your PoCC (or line manager for LGFS/FSD) who will discuss the correct process with you. They will then need to contact the firms KAM (T&C Oversight for LGFS/FSD) for their explicit approval. The KAM or T&C oversight will then be required to add notes to the POS record confirming their approval and any before a case can proceed.



5.2.1 PROTECTION SUITABILITY

LETTER (GENERAL REQUIREMENTS)

Please ensure that the letter looks and reads like a professionally produced document. For example, make sure it is grammatically accurate, spelt and punctuated correctly, and does not contain large areas of upper or lower case letters where it is inappropriate to do so.

PSL GENERAL REQUIREMENTS - FUNDAMENTALS

Customers must receive a letter that clearly explains what your recommendation is (product detail, term etc.), why it is suitable (the shortfall that the cover prevents), and how it meets their needs (what it does to meet the need). It must also detail any shortfalls in cover, or any areas where claiming may be impacted.

Your PSL must be issued to the customers by the earliest of: Within eight days of their definite decision to proceed with a protection product The policy going on risk Mortgage exchange or missives in Scotland (where any mortgage protection for life assurance or critical

illness are arranged)

If the customer requires that part of your recommendation be placed on risk immediately but hasn’t decided on the remainder of your recommendation, you must give separate PSL letters (one for the business placed on risk immediately and one for the remainder of the recommendation) and confirm within them that they should be read in conjunction with each other

If any delay occurs in issuing the PSL, a note must be added to explain the reason for the delay

Joint customers who reside at different addresses must both receive a PSL letter

Should two or more advisers be involved in making a recommendation to a customer (e.g. for different products) then each will need to issue a PSL for their part of the advice given

If customers require part of a recommendation be placed on risk immediately (and they have made a full and final decision on the remainder of the protection recommended), then the content normally required within a PSL must be verbally disclosed to them, with a finalised version of the document issued to them in the best format for them to receive it in the quickest time (e.g. email, by hand etc.)

You must ensure that any existing policies, and your recommendations relating to them, are detailed in the Protection Suitability - Existing Policy Supplement




LETTER (RECOMMENDATION

CHECKSHEET)

No Product Type or Customer Situation

Detail required in PSL

1

All PSL must include:

The reason for the meeting

The areas of protection you have reviewed

The areas of protection that the customer did not wish to discuss

2 All (and for each policy type)

An explanation of what the recommendation is, and how it will specifically meet the need of the customer

3 All Detail of any area of need not covered, partially covered, or not addressed, the reason for

this and the implication to the customer (either within the detail of your recommendation, or within the shortfall section)

4 All The total monthly cost of all accepted policies

5 All If you haven’t been able to recommend a product due to ineligibility or non-suitability of that

product, you must add an explanation for the reasons or circumstances that have led to that decision

6 All Any other relevant information that explains why your recommendation is suitable to the

needs of the customer (e.g. discussions relating to employer benefits)

7 All Confirmation if any other product will be discussed with another adviser, and that you have

not given advice in relation to that product

8 All (additional policy options)

An explanation of the benefit of any additional options that were recommended/chosen, and why they were considered suitable to the customers circumstances and needs, and that customers are aware of any extra cost involved in taking them

9

Where chosen solution results in a significantly different outcome from your recommendation

Explain how the chosen solution still results in the right outcome for the customer. Examples of when this would be required would be: DTA/LTA chosen when FPIP recommended, MTA chosen when MDTA recommended, single policies chosen when joint policies recommended, or longer deferred period taken when shorter recommended. Where the chosen solution doesn’t result in the right outcome or there is no explanation, we would not expect the policy to be applied for as we do not allow execution only sales.

10 If reviewable premiums chosen

Include risk warning re potential increases in premium

11

Where a secured/unsecured loan is to be covered by MDTA or DTA

Include a statement that you have made the customer aware that the policy assumes an interest rate of 9% or less. As loan rates are typically higher than for a regulated mortgage, if the rate does or is exceeding 9% there may be a shortfall in cover and MTA may be more appropriate

12 Life, CIC or FPIP If customer requires additional cover than that recommended or would normally be

considered feasible, then the reason for the additional cover must be explained

13

ASU chosen but policy restrictions make it difficult to claim, but customer wants to proceed

An explanation of why they may not be able to claim, and the reasons and circumstances under which they believe that the policy is still suitable for them

14

If product recommendation accepted (IPB, ASU)

Explanation why the deferred period recommended is suitable to customers’ needs

Explanation why the amount of cover and the term of cover are suitable to customers’ needs

Explanation why any additional features extras were recommended and confirmation that the customers are aware of the additional cost of taking them

Any period where the customer would not receive benefits, have reduced cover, or they have no cover at all, and an explanation of why this is still considered suitable

Any periods of excess cover (ASU), and why this is considered suitable

Reason why this cover would be required, where existing cover/employee benefits or provisions exist

15

If product recommendation accepted (IPB)

Confirmation is required that you have had a discussion that ESA is only payable where customer is eligible and may mean reduced benefits are payable in claim, or a shortfall may exist if they were taken into account when recommendation took place but subsequently not eligible for ESA



16

If product recommendation accepted (IPB only)

If customer receives benefits in excess of 12 months, your PSL will need to detail that the customer understands and is agreeing to proceed, even though there will be a period of ‘x’ reduced or no policy benefits will be paid in claim. This means that they may be paying a premium on a policy that will only pay out after a period of sickness/incapacity of ‘x’ months

17 If product recommendation accepted (ASU only)

If customer is ineligible to claim (e.g. due to pre-existing condition) but other parts of policy are still considered acceptable, an explanation must be given as to why the policy is still considered suitable


If customer is currently on maternity leave, they must return to work prior to being able to be eligible to claim


If the exception process was invoked by the customer meaning the prohibition period doesn’t apply, detail the circumstances of how that came about

20

If product recommendation declined (IPB/ASU combined sale only)

Where you have recommended a combination of ASU and IPB to provide the best customer outcome, but the customer declines the AS or ASU element following the expiry of the prohibition period, then you must ensure the customer is made aware of any shortfall in cover that exists. If the chosen solution subsequently changes, issue an addendum letter to the customer

21 If ASU switcher option utilised

Include a risk warning that the customer will only receive the benefit amount payable on the original policy if a claim occurs within the qualifying period of 60 days

22

If product recommendation accepted (U for self-employed only)

Confirmation that your self-employed customer is fully aware of the procedures and evidence required in order to claim under the U element of the policy (and detail those procedures as documented in the policy booklet)

23

If product recommendation accepted (Family Protection)

An explanation of why the amount of cover and the term of cover are suitable to the needs of the customers

24

Lifestyle (where your recommendation isn’t completely declined)

If an ASU recommendation is subject to a prohibition period (see Section 3.7.2), you should include the following statement in your PSL – ‘This policy is subject to a prohibition period and cannot be chosen until seven full days after your mortgage offer/personalised illustration is received by you (whichever is the later). I will contact you after this period to discuss your decision relating to this policy and whether it is still suitable for your needs’

Once prohibition has ended, you must then finalise your advice. This can be done by either:

Issuing a Lifestyle cover addendum letter if the customer accepts or partially accepts your recommendation following the prohibition period.

Issuing Letter 2 if the customer declines all of your recommendations (not just ASU)

25

Customer has not accepted your full recommendation (e.g. partial accept)

Detail all the consequences (shortfalls) of the customer taking only part of your recommendations, including if the sum assured, monthly benefit amount, deferred period or policy term are altered. The same applies if any part of your recommendation is changed due to affordability

26 Wills The PSL has standard wording for this. Ensure that you edit it so that it’s appropriate to your

customers personal situation

27 Trusts (Single Life Policies Only)

Where the primary recommendation is to cover critical illness and the customer is unconcerned where proceeds of Life cover will go in the event of their death, then this situation must be clearly documented in the PSL

28

Trusts (Single Life Policies only)

PSL must confirm:

That a policy has been recommended to be placed in trust and why

Where recommendation to place in trust declined, an explanation of why declined

The risks and consequences of not placing the policy in trust

If policy is likely to mean that nil tax band is exceeded, that the customer seeks specialist tax advice

The importance of completing and returning forms

29 Trusts (Joint Life Policies Only)

Although we would not normally expect a joint policy to be placed in trust, where it is, we expect an explanation of why this would be suitable

30 Life of another recommendation

An explanation as to why Life of another is suitable, and appropriate risk warnings to cover the points in detailed in Section 3.7.6

Within the PSL - existing policy supplement

1 If an existing policy is to be cancelled

You must explain that it is the customer’s responsibility to ensure that any 3rd

party policy is cancelled at the appropriate time.

2

If you’re recommending cancellation of existing policies

You must make a recommendation to retain or cancel these policies. Where cancellation is your recommendation, you must explain the reason for cancelling and why the product you’re recommending is more suitable.



Within the PSL - existing policy supplement (continued)

3

If you’re recommending cancellation of existing policies

You must detail any material differences between the existing policies and your recommended replacement

4 If policy being cancelled is a TELIP

You must point out that tax efficiency will not be transferred to the new policy

5

If you’re recommending cancellation of existing CIC policies

Detail any cover being lost, or potential change in the ability to claim, or restrictions that may apply

6 If you’re recommending that a CIC policy is retained

Explain how the policy meets the current needs of the customer

7

If customer hasn’t provided sufficient policy details during fact finding

You must make it clear that these policies have not been included in the advice you have given and why (note – if sick pay benefits not received, no recommendation for Income Protection can be made)




LETTER (WHEN TO RE-ISSUE YOUR

PSL)

PSL WHEN TO RE-ISSUE - EXCEPTIONS

Where the customer’s chosen solution is altered so that the premium increases, you should re-confirm that the solution is affordable and add notes to the POS record to confirm whether the customer is to proceed or not. There’s no need to re-issue your PSL letter in these circumstances

PSL WHEN TO RE-ISSUE - FUNDAMENTALS

You must re-issue your PSL if matters arise that cause you to reconsider the suitability of your recommendation or you re-visit your advice. For example if: Rated cover affects the affordability of your recommendation You’re made aware of a change in the customer’s circumstances affecting the suitability of a policy You’re provided with crucial additional information

You don’t need to re-issue your PSL if an underwriting decision results in an exclusion or postponement of cover. However, an addendum letter will need to be issued to the customer and attached to the POS record. This letter must detail and exclusion or postponement and confirm any resulting shortfall.



6.0 REFERRING (TO THE CENTRAL

ADVICE UNIT)

6.1 GENERAL CONDITIONS

6.2 REFERRAL REQUIREMENTS

6.3 REFERRAL PROCESS

6.4 EXCEPTIONS AND VARIATIONS



6.1 GENERAL CONDITIONS

CAU GENERAL CONDITIONS - FUNDAMENTALS

These standards only apply to firms that have taken the CAU proposition and those advisers that have received the appropriate training

For life, critical illness and income protection, there will be certain instances (or triggers) when you may wish to refer your customer to a specialist Legal & General adviser team, the Central Advice Unit (CAU), who have access to a panel of providers, and who may be able to meet the needs of customers where Legal & General are unable to do so

The referral process mustn’t be discussed with the customer until such time as a trigger has been identified

A trigger may occur if:

Legal & General underwriters will decline or have declined to cover the customer; or

Legal & General will rate or have rated a policy

You should explain to the customer, prior to referral, that the CAU is a telephone based protection advice team, employed by Legal & General. The unit have access to a limited panel of providers, which can include Legal & General. You must have your customers explicit approval to refer them prior to passing their details to the CAU

Both the Network adviser and CAU adviser are solely responsible for the advice they give in the areas of protection they’re recommending

Where a trigger occurs post application and a referral is made, the CAU adviser may need to re-visit any other protection the Network adviser has applied for if affordability becomes an issue at that point. This will allow the CAU adviser to re-confirm the customer’s priorities and to recommend the best solution to obtain the right customer outcome. In these cases, the CAU adviser will inform you so any submitted protection can be stopped, excluding B&C applications.

Between the CAU adviser and the Network adviser you:

Can discuss generically, the products and areas of need and how best to ensure these are met. For example, you can ascertain the need but not discuss product features or level of cover

Cannot steer the other adviser in any way and they must not steer you as to what your advice must be

Must ensure that your record keeping must be of the highest quality and notes must be comprehensive

Each adviser remains responsible for the advice they each give to the customer and, following discussions, they must each be satisfied that the recommendation that they’ll personally make to the customer is suitable

Where policies are rated and you refer this to the CAU, you must price match before referral

Both advisers should formulate and agree that their individual recommendations are affordable and that the overall outcome is suitable for the customer, and confirm why this is the case in the PSL

Any relevant existing life, critical illness and income protection policies must be forwarded to the CAU where required. If preferred the customer can send directly to Central Advice Unit, Legal & General House, Bay 305, St Monica’s Road, Kingswood, Surrey, KT20 6EU



.

CAU GENERAL CONDITIONS - FUNDAMENTALS (cont)

Fee waiver agreements can’t be invoked on any policies sold by the CAU. They can only be invoked on Legal & General policies you’ve sold

The combined recommended package from both the Network adviser and CAU adviser must be within the customer’s surplus income as recorded in the fact find



6.2 REFERRAL REQUIREMENTS

CAU REFERRAL REQUIREMENTS - FUNDAMENTALS

If a customer is referred for CIC cover, then life must also be referred

If a customer is referred for Life cover, then CIC (where applicable) must also be referred

ASU does not need to be referred with Income protection. However if matters arise that result in the CAU re-visiting the ASU recommendation, they will inform you and the ASU application must be stopped

If it’s apparent that the customers’ needs are best met with a joint policy and a trigger occurs for one customer, then both customers must be referred, unless the accepted customer wishes cover to start immediately

If it’s apparent that the customers’ needs are best met with single policies and a trigger occurs, then only the customer to whom the trigger applies needs to be referred

Where the customers have an existing joint policy and a trigger is reached, then refer both customers even if the recommendation is for two single life policies and only one customer meets the required trigger (unless the accepted customer wishes cover to start immediately). This is because when giving advice on the new policies advisers will have to take into account the existing joint life policy and therefore two advisers may give conflicting advice

If a need for family protection has been identified and agreed, and the customer is being referred for life/CIC, then family protection must also be referred



6.3 REFERRAL PROCESS

Step Instruction

1 Produce the CIDD/IDD in the usual way

2 Complete the fact find

3 If a trigger occurs, and the customer agrees to a referral, the customer consent form (which can be found in POS library) should be read to the customer

4 You should then prioritise the customer’s requirements in the notes section of the protection tab. If the customer is purchasing a freehold property, buildings insurance should be the top priority, everything else will be down to a discussion with them

5 Notes should be added to the record confirming that customer consent has been obtained using the following wording – ‘I’ve read the full customer consent wording to the customer(s) and the customer(s) has/have provided explicit verbal consent to refer his/her/their personal information to the CAU’

6 Confirm to the customer that the referral will be made and that the CAU will then attempt to contact them on the same working day if referral received before 12pm or the next working day if after 12pm or on the day and time specified by the customer

7 Inform the customer that if they purchase a product from the CAU, you’ll receive a fee in the form of commission

8 If the customer doesn’t consent to the referral, you should recommend protection to cover the customer as per Section 3.7 of these standards in the normal way. The resulting PSL must detail any shortfall in cover, the reason for the shortfall and any consequences

9 Complete the CAU referral form and email to the unit’s inbox [email protected] or fax to 0845 071 1665. The completed referral form should be attached to the POS record. (The referral form can be found in the literature library)

10 The CAU will acknowledge the referral via email, confirming that the customer has been contacted. This email should also give you a CAU reference number, which you should record in the POS record notes

11 For urgent customer contacts, you should phone the CAU on 0845 674 0800 and agree a time suitable for them to contact the customer

12 In all circumstances, the PSL should clearly state the reason for the referral. If the customer declines all recommendations, then details for the referral should be put in POS notes

13 Ensure that the recommended solution in the PSL is within the customer’s surplus income as recorded in the fact find

14 If the customer rejects your offer to refer, the PSL must clearly state that the referral recommendation has been rejected and give a reason why

15 If the customer declines to proceed with all of your recommendations, or fails to confirm their chosen option, you don’t need to issue a PSL. However, you must issue a letter (and attach it to the POS record) explaining that needs were identified but the customer didn’t want to address them and rejected your referral recommendation. A template of this letter is available in the POS library (Letter three PAS)

16 If Legal & General have rated the customer, notes should be added to the POS record detailing whether the customer is happy to accept the increased premium, and/or whether a referral has been offered. If a referral is made, you must price match before referral

. Where necessary, you’ll need to keep the CAU informed of: Mortgage exchange/completion dates to ensure the CAU recommendation is placed on risk at the appropriate time

Any changes to the mortgage, which will affect the CAU recommendation

Any change in customer circumstances

Any change in recommendation affecting affordability When the CAU advise you of the CAU case reference number, you must add this to your case notes to show that the records are linked. If a customer initially agrees to be referred but subsequently changes their mind, the CAU will inform you in order that you can resume the advice process, if possible.




6.4 EXCEPTIONS AND VARIATIONS

CAU EXCEPTIONS AND VARIATIONS - FUNDAMENTALS

If a trigger occurs post application and the customer declines your referral, you should issue an addendum letter to the PSL confirming that the customer has rejected your referral recommendation and attach this to the case

If there’s an affordability issue and it has been determined that a trigger will occur, all identified needs should be referred to the CAU, with the exception of Buildings and/or Contents. Where a need has been identified in this area, the Network adviser should recommend B&C before the referral is passed to the CAU

If matters arise that cause your recommendation to change, you must re-visit your advice and update the CAU. The CAU will update you as and when is necessary



INDEX

A

Affordability Page 9, 14 Aims and Views (Identifying) Page 10 Aims and Views (Table) Page 11 Applications Page 9 Available Funds (Definition) B

Binder Requirements Page 33 Budget Planner Pages 8, 9 and 18 Buy to Let (covering a mortgage) Page 22 Buy to Let (covering a property) Page 28 C

CAU Referrals (General Conditions) Page 40 CAU Referrals (Requirements) Page 42 CAU Referrals (Process) Page 43 CAU Referrals (Exceptions) Cease to Trade Page 15 CIC cancellation Pages 19, 20 and 21 Credit agreement wording (GI - Buildings and Contents) Page 27 D

Death in Service Page 8 Didn’t wish to address Page 11 Didn’t wish to discuss Page 11 Director Page 15 Disclosure Document Pages 4, 5, 25 and 33 E

Eligibility Pages 14, 17 and 25 Employer Benefits Pages 8, 15, and 24 Execution Only Pages 4, 13 and 27 Exceptions (definition) Page 3 Exceptions Process (Lifestyle cover) Page 25 Exclusions Page 14 Existing Policies Pages 7, 19 and 20 Existing Policies (3

rd Party Policies) Pages 8 and 21

Existing Policies (Retaining or Cancelling) Page 19 and 20 Existing Policy Supplement Pages 19, 21 and 34 Expenditure Page 9 F

Fact-finding Page 7 Family Protection Page 26 Flexibility Options Page 8 Foreign Nationals Page 59 Formulaic Approach Page 13 Fundamental (definition) Page 3 G

Guaranteed Insurability Options Page 8 Guaranteed Premiums Pages 10 and 17 H

Houseperson Pages 24 and 25 ‘How do you wish to address’ boxes Page 11 I

Immediate Risk cases Pages 5 and 34 Impact Boxes Page 11 Introduction Page 3



K

Key Features Documentation Page 14 L

Licences Pages 4, 13, and 22 Life of another Page 30 Lifestyle Cover Page 25 Lifestyle Need (Protecting) Page 27 Lifetime Mortgage (Protecting) Page 22 Limited Disclosure Page 5 M

Mandatory Product Disclosure Guidance Page 13 Maternity Leave Page 25 Mortgage Protection Page 22 N

Non-Advised Sales Pages 4 and 13 Not Permitted Areas (definition) Page 3 O

Occupations Page 14 OLPC Page 31 Over 50’s plan Pages 4 and 13 P

Policy Options Page 14 Policy Suitability Pages 14 and 15 Postponement of cover Page 38 Pre-Existing Conditions Page 15 Prohibition period (ASU) Pages 25 and 26 Property and Contents (Protecting) Page 28 Protecting an Income Page 24 and 25 Protecting a Lifestyle need (CIC) Page 27 Protecting a Mortgage Page 22 Protecting a family Page 27 PSL (General Requirements) Page 34 PSL (Checksheet) Pages 35 and 36 R

Rated Cover Pages 18, 38 and 41 Recommending (General) Page 13 Redundancy Pages 8 and 15 Regulatory Responsibility Page 3 Re-issuing your PSL Pages 18 and 38 Reviewable Premiums Pages 10 and 17 S

Scope of Service Pages 4,5,7,8,11,19 and 29 Self-Sales Page 33 Separated Advice Process Page 7 Single Policies Pages 23 and 43 Shared Equity Loans Page 22 Shared Ownership Mortgages Page 23 Shortfall Pages 5,9,11 and 18 Sole Trader Page 15 State Benefits (IPB discussion) Page 24 Suitability Page 14 Switcher Cover Page 15 T

Telephone Sales Pages 4 and 5 TELIP Page 20 Trusts Pages 7 and 30 U

Underwriting Pages 20,31 and 38 Unemployment Cover Pages 15, 20 and 24 Unlimited Liability Partnerships Page 15



V

Verbal Disclosure (Protection) Pages 5,22,24,27 and 28 Verbal Disclosure (GI – B&C credit agreement) Page 28



ANNEX A – MANDATORY PRODUCT

DISCLOSURE GUIDANCE

MANDATORY PRODUCT DISCLOSURE GUIDANCE – PROTECTION PRODUCTS

CONTENTS

Buildings and contents (B&C) Decreasing term assurance (DTA/MDTA) Decreasing term assurance and critical illness (DTACIC/MDTACIC) Family and Personal Income Plan (FPIP) Family and Personal Income Plan and critical illness (FPIPCIC) Income Protection Benefit (IPB) Lifestyle Cover Accident, Sickness and Unemployment (ASU) Level term assurance (LTA/MTA) Level term assurance and critical illness (LTACIC/MTACIC)



ANNEX B - POLICY SUITABILITY

GUIDE

Product Customer currently living abroad

Customer has plans to move outside UK

Customer spends time outside UK

Customer plans to stay in UK (foreign nationals)

Life & CIC

all must apply:

Customer must have a UK address and

Bank Account

Customer must have a UK address and Bank

Account

Customer must have a UK address and Bank Account

Customer must have a UK address and Bank Account

Customer must have 'vital interests' in the UK, e.g. a UK home

address

If there are no firm plans to move abroad then it should be possible to

consider terms. Future residency is only taken

into account where there is a definite intention to

move abroad

Travel within the European Union (EU), United States of

America (USA), Canada, Australia and New Zealand must be temporary, i.e. they

must be intending to return to the UK

Travel to countries not listed above, that are offered terms

in Life Guide, must be temporary, i.e. they must be intending to return to the UK

Life and CIC can be sold to anyone who is buying a property in the UK as long as the property will be their

main residence

Return to the UK must be intended, i.e. the

residency / travel must be on a

temporary basis

Where permanent move abroad is imminent, i.e. planned move less than minimum policy term =

Decline

Customer has valid justification for effecting a

policy in the UK

The customer must be in the UK at the start of the policy, have the right to reside in the UK and should be

intending to stay in the UK a minimum of two years

Customer has a valid justification for

effecting a policy in the UK

Where planned permanent move abroad is over our minimum policy term, the

following applies: UK mortgage - Allow cover for full mortgage term (copy of loan offer letter is not required)

Non-mortgage - Allow cover for remaining period

of stay in UK (e.g. until visa expires)

If residing outside of the UK regularly, patterns of future

and past residency will need to be considered

Application Details UK mortgage - Allow cover for full mortgage term (copy of loan offer

letter isn't required) Non-mortgage - Plans to remain in

the UK indefinitely: If the customer is resident in the UK

on a temporary visa but plans to remain in the UK indefinitely (evidence of this includes an

intention to apply for indefinite leave to remain, married / in a civil

partnership with a UK citizen [or planning to do so], joint life

application with a UK citizen, customer has bought a UK property

with the intention to stay in the UK ) - allow cover for the full term

requested No plans to remain in the UK

indefinitely: If the customer is resident in the UK on a temporary visa but doesn't plan to remain in the UK indefinitely - limit policy term to match the remaining

visa term

If the customer is outside the United Kingdom (UK) for

more than 12 months in a two-year period a claim under Critical

Illness Cover may be declined (updated 18

July 2011).

If the customer is outside the United Kingdom (UK) for more than 12 months

in a two-year period a claim under Critical Illness

Cover may be declined (updated 18 July 2011).

If the customer is outside the United Kingdom (UK) for more than 12 months in a two-year period a claim under Critical

Illness Cover may be declined (updated 18 July 2011).



IPB

We don't normally accept requests for disability benefits for customers who are currently residing outside of the UK or who have definite plans to move abroad within the term of the policy. It may, however be possible, in some circumstances, to accept cover:

For customers resident in the Isle of Man and Channel Islands subject to normal underwriting criteria. However, it should be remembered that levels of state benefits may differ from the UK, although this will not affect benefit calculation at underwriting stage.

If the customer is temporarily travelling to a country that is acceptable at standard rates in Life Guide, we can offer terms as long as the travel is not more than six months in total. Care needs to be taken when considering accepting this business as all policies with disability benefits contain a standard exclusion wording relating to foreign residency and travel. It's not acceptable to recommend cover that would not pay out at claim stage due to this exclusion

IPB can be sold to anyone who is buying a property in the UK as long

as the property will be their main residence

ASU

The customer must have the right to live in, and be a permanent resident of, the UK, Channel Islands or the Isle of Man for as long as the policy is in force. Customers without the right to live (or not working) in the UK , Channel Islands or Isle of Man are

not potentially suitable for ASU (unless they work for the Armed Forces, Civil Service or a company registered in the UK, Channel Islands or Isle of Man and the customer is required to work within the EU)



ANNEX C – AIMS AND VIEWS

SCREENSHOT



GLOSSARY

APER - Approved Person

ASU - Accident, Sickness and Unemployment Cover

AR - Appointed Representative

B&C - Buildings and Contents Insurance

BTDO - Back to day one cover

BTL - Buy to Let

CIC - Critical Illness Cover

CIDD - Combined Initial Disclosure Document

CAU - Central Advice Unit

DTA - Decreasing Term Assurance

ESA - Employment and Support Allowance

FCA - Financial Conduct Authority

FPIP - Family Protection Income Policy

GI - General insurance

GIO - Guaranteed Insurability Option

HMRC - Her Majesty’s Revenue & Customs

IDD - Initial Disclosure Document

IHT - Inheritance Tax

IPB - Income Protection Benefit

IVA - Individual Voluntary Arrangement

KAM - Key Account Manager

LTA - Level Term Assurance

MDTA - Mortgage Decreasing Term Assurance

MTA - Mortgage Term Assurance

MUTAL - Medical Underwriting Technical Advice Line

OLPC - On-line Protection Connect

PoCC - Point of Compliance Contact

POS - Point of Sale (the system used to record and process sales)

PRIN - Principles handbook published by the FCA

PSDD - Point of Sale Disclosure Document

PSL - Protection Suitability Letter

T&C - Training and Competency

TCF - Treating Customers Fairly

TELIP - Tax Efficient Life Insurance Plan

TPD - Total and Permanent Disability

U - Unemployment Cover

LEGAL & GENERAL NETWORK PROTECTION AND GENERAL INSURANCE … · INSURANCE ADVICE STANDARDS...

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Transcript of LEGAL & GENERAL NETWORK PROTECTION AND GENERAL INSURANCE … · INSURANCE ADVICE STANDARDS...