Screening and Monitoring Changes at BridgeForce
March 2015
New forms New questions BridgeForce Compliance website BridgeForce Contracting issues
Agenda
Screening Confirmation Request ◦ Designed by insurers to allow MGAs to ask about
advisors moving MGAs
New Screening Forms
1. Status of the contractual relationship between insurer and advisor?
2. Any unresolved debts with the insurer? Efforts to repay?
3. If contract was terminated, would insurer consider re-contracting?
Has company investigated or reviewed a concern/complaint related to market conduct?
Questions Asked
Advisor Screening Questionnaire (ASQ) ◦ Looks like the old CLHIA application for contract ◦ Now asks you if you have
Documented AML program Written privacy program Written disclosure statement Needs-based selling practices
New Screening Forms
You need to have all of these – these are old requirements◦ AML Compliance Regime – since 2008◦ Privacy Program – since 2004◦ Written disclosure statement – since 2004◦ Needs-based selling practices – since the dawn of
time (or 2005 when CCIR endorsed the CLHIA Approach)
Impact on Advisors
Having asked the questions, there may be legal exposure in doing nothing.
Advisors have 3 months from being contracted to get everything in place.
MGA Guidance
When you apply for a contract with an insurer through us, you will be asked to sign the Code and certify either that
◦ 1. You are compliant OR
◦ 2. You have gaps you have identified and you will repair them within 3 months.
◦ At the end of 3 months, you will be asked again to certify that you are compliant. If you cannot, we contact the insurer for instructions.
BridgeForce Code of Conduct
http://bridgeforcefinancial.com/toolbox/compliance/ - It’s all there for you –
- Anti-Money Laundering Tools- Privacy Tools- Point of Sale Disclosure- Needs Analyses and KYC
And plenty more than that!
BridgeForce makes tools and templates available to you
MGAs are expected to engage in risk-based monitoring of advisors.
Where necessary, we may have to review your business.
You are expected to cooperate and produce records and files.
Enhanced Monitoring
Regulators say insurers are responsible for the conduct of their agents – even independent agents.
Insurers delegate some of the responsibility to MGAs, who act on behalf of the insurers.
This is the regulatory framework we now all operate under.
Why should I allow this?
New screening documents are already being used.
Behind the scenes monitoring has always gone on.
How will this be rolled out?
BridgeForce does not intend to institute formal “audits” but will do some reviews and sampling in agent files to satisfy itself, insurers and regulators that
1. It knows its advisors 2. It takes reasonable efforts to detect and
prevent fraud and unacceptable sales practices.
3. It complies with Anti-Money Laundering and Anti-Terrorist Financing regulations.
What about reviews?
Most will be based on random selection
We hope to provide something in return, including pointers, sample material, templates to use.
More on reviews
Reviews can assist you in improving your practices and protecting you from unpleasant surprises.
BridgeForce has committed itself to helping advisors get compliant.
The upside?
Please take part in the AML workshop this afternoon.
BridgeForce Compliance Days are a big part of that
Questions?
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