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This communication was created by Advisable Wealth Engines. Neither Great-West Life & Annuity

Insurance Company (GWLA) nor any of its subsidiaries have reviewed or approved the material

provided and are not responsible for the content and/or updates with respect to this material. GWLA

and its subsidiaries are separate from and unaffiliated with Advisable Wealth Engines. The PPVUL

product referenced herein is issued by GWLA or an affiliate thereof. Variable universal life insurance

policies and appropriate state variations are issued by GWLA. GWLA is not licensed to do business in

New York. Policies may not be available in all states. Certain restrictions apply. U.S. Patent No.

8,660,863 under license from Paul F. Berlin LLC

Illustration Illustration Illustration Illustration GamesGamesGamesGames

Tactics Used in Life Insurance

Illustrations to Hide a

Private Placement

Variable Universal Life (PPVUL)

Policy’s Weaknesses

Illustration Games

FOR INVESTMENT PROFESSIONAL USE ONLY

2

hen considering investing in

a life insurance policy, the

insurance company is to

furnish the potential policy

owner with a proposal that includes a

financial illustration (“Illustration”). The

Illustration’s content and presentation

are detailed in the “Life Insurance

Illustration Model Regulation (Model

#582)” published by the National

Association of Insurance Commissioners

(NAIC).

The regulation’s purpose is clearly

articulated in the summary:

“The purpose of this regulation is to

provide rules for life insurance policy

illustrations that will protect consumers

and foster consumer education. The

regulation provides illustration formats,

prescribes standards to be followed

when illustrations are used, and

specifies the disclosures that are

required in connection with illustrations.

The goals of this regulation are to ensure

that illustrations do not mislead

purchasers of life insurance and to make

illustrations more understandable.

Insurers will, as far as possible, eliminate

the use of footnotes and caveats and

define terms used in the illustration in

language that would be understood by a

typical person within the segment of the

public to which the illustration is

directed.”

An Illustration’s Required An Illustration’s Required An Illustration’s Required An Illustration’s Required CompoCompoCompoCompo----

nents: NAICnents: NAICnents: NAICnents: NAIC

Essentially, an Illustration provides a

year-by-year projected cash-flow

analysis based on a set of assumptions.

For a “Basic” Illustration, the mandate

directs certain assumptions that

determine the value – if not viability – of

the insurance contract. Although an

illustration has a number of required

elements, its financial presentation must

include these items:

• Year-by-year analysis beginning with

the insured’s current age through to

ending age 100, policy maturity or

policy expiration.

• Specific timing elements defining

invested premium, costs, and

payouts.

• Guaranteed elements – policy

benefits, premiums, values, credits

WWWW

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3

and charges determined at issue – are

presented before more favorable

non-guaranteed charges (often called

“current” charges) and for the same

duration.

“This [showing guaranteed charges]

is the legally required disclosure of a

worst-case scenario. It outlines policy

performance based on the carrier’s

minimum filed credit rates for a

particular policy and the maximum

mortality charges based on the . . .

standard mortality table. . . . CPAs

studying insurance policy

illustrations can assume the benefits,

cash surrender value and

accumulated values will never be

lower than those the insurer

guarantees.” (Journal of Accountancy;

“Understanding Life Insurance Illustrations”;

February 1, 2003)

The focus on guaranteed charges

reflects a caution related to the long-

term nature of a life insurance policy;

one that can last decades. These

charges are the insurance company’s

contractual obligation to each policy

owner and underlie the reality that a

given company’s strategy, stability, and

operations may not, 20 or 30 years later,

be what they are today.

The “today” status is shown in the

Illustration’s “non-guaranteed” charges

that are at the insurance company’s

discretion and assume an operational

steady-state forward from the

“[insurance] company’s actual recent

historical experience”. These non-

guaranteed charges give the most

favorable cost picture for the policy.

An Illustration’s Required An Illustration’s Required An Illustration’s Required An Illustration’s Required CompoCompoCompoCompo----

nnnnents: FINRAents: FINRAents: FINRAents: FINRA

Variable Universal Life (“VUL”) policies

are securities and regulated by FINRA.

Therefore, in addition to the NAIC rules,

FINRA has additional requirements for

VUL illustrations. With a focus here on

the financial due diligence necessary for

a wealth advisor’s prudent product

analysis, the related FINRA Illustration

elements are:

• “An illustration may use any

combination of assumed investment

returns up to and including a gross

rate of 12%, provided that one of the

returns is a 0% gross rate. Although

the maximum assumed rate of 12%

may be acceptable, members are

urged to assure that the maximum

rate illustrated is reasonable

considering market conditions and the and the and the and the

available investment available investment available investment available investment optionsoptionsoptionsoptions.

[Emphasis added].

The purpose of the required 0% rate

of return is to demonstrate how a lack

of growth in the underlying

investment accounts may affect policy

Illustration Games


4

values and to reinforce the

hypothetical nature of the

illustration.”

• “The illustrations must reflect the

maximum (guaranteed) mortality and

expense charges associated with the

policy for each assumed rate of

return. Current charges may be

illustrated in addition to the maximum

charges.” (Source: http://finra.complinet.com/en/

display/display_main.html?rbid=2403&eleme

nt_id=3619&print=1)

The FINRA illustration regulations force

the analysis on the policy’s inherent cost

structure. This is reflected as: “Will the

policy’s filed costs support its death

benefit value under a worst-case

scenario?”

FINRA pushes this comparison of what is

known and promised (guaranteed)

versus what is hoped for and

discretionary (i.e. non-guaranteed

charges with year-by-year return

assumptions up to 12%) because the

due diligence evaluation of an

investment with a decades-long profile

must anticipate changes to an assumed

steady state. This may be unfavorable in

a typical sales scenario but is essential

for a fiduciary.

A Required Component of the A Required Component of the A Required Component of the A Required Component of the

Application PackageApplication PackageApplication PackageApplication Package

While noting the sales presentation

materials and personal engagement that

exists between a potential policy owner,

the wealth advisor, and insurance

consultant/agent, the core component

determining a policy’s investment and

wealth-planning fit – the due diligence

evidence - rests with the Illustration.

This emphasis is brought into focus as

the NAIC requires it within the

application process. The NAIC reflects

on the Illustration as:

“The requirements essentially state that

if the marketing of the policy includes an

illustration and the policy is applied for

as illustrated, the authorized company

representative must submit the

illustration, signed by that

representative and the applicant, to the

insurer at the time of policy application.

. . . If an illustration is presented prior to

application and is later revised before

the policy is issued, the new illustration

must be labeled ‘Revised Illustration’. In

FINRA pushes this comparison of what is known and promised (guaranteed) versus what is

hoped for and discretionary . . . because the due diligence evaluation of an investment with a

decades-long profile must anticipate changes to an assumed steady state. This may be

unfavorable in a typical sales scenario but is essential for a fiduciary.

Illustration Games


5

all cases where an illustration is

required, the policy applied for or issued

must have an illustration accurately

representing the policy and

appropriately signed by the applicant or

policy owner and the authorized

company representative. The illustration

must be provided prior to or

simultaneously with the policy delivery.” (Source:12/13/2017; http://www.naic.org/

cipr_topics/topic_life_insurance_illustrations.htm)

Illustration Games


6

PPVUL Illustrations: Setting the PPVUL Illustrations: Setting the PPVUL Illustrations: Setting the PPVUL Illustrations: Setting the

StageStageStageStage

Variable Universal Life insurance

policies, provide varying premiums,

death benefits, and investment options

(hence the term “Variable”).

A segment of the VUL product class is

Private Placement VUL (“PPVUL”). Unlike

other life insurance products that

emphasize the death benefit as the

wealth planning application, PPVUL

changes the priority to maximizing the

invested premium relative to the death

benefit. Taking this approach utilizes

PPVUL’s tax-free investing advantage for

a family’s investment plan (as long as the

policy remains in force until the insured’s

death) that typically results in family

wealth increasing at an accelerated rate.

This maximize-cash-value-to-death-

benefit relationship targets families with

excess wealth indicative of qualified

purchasers; those defined in the

Investment Company Act of 1940 as

having investable wealth greater than $5

million.

Source: https://news.harvard.edu/gazette/story/2016/04/for-life-expectancy-money-matters/

Longevity and Longevity and Longevity and Longevity and Wealth RelationshipWealth RelationshipWealth RelationshipWealth Relationship (1.4 billion Internal Revenue Service records (1.4 billion Internal Revenue Service records (1.4 billion Internal Revenue Service records (1.4 billion Internal Revenue Service records

onononon income and life expectancy)income and life expectancy)income and life expectancy)income and life expectancy)

Exhibit 1

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7

Unique and Proprietary The Great-West Life & Annuity Insurance Company’s (“Great-West”) PPVUL policy for HNW investors offers a compelling set of features compared to common PPVUL policies offered by other insurance companies:

• Guaranteed charges even to ages greater than 100 (removing the cost risk)

• The guaranteed charges eliminate lapse risk due to unplanned cost increases

• An age-based underwriting factor, multiplied by the policy’s cash value, enables an easy, anytime death benefit calculation

• A death benefit booster that increases family wealth even above the compounded tax-free portfolio’s value

• The guaranteed charges, com-bined with the death benefit booster, give straight profits net of policy charges (even past age 100)

• A single, asset-based charge for simple administration at any age (male or female; smoker or non-

smoker)

A PPVUL’s long-term investing role is

accentuated by substantially longer life

spans for wealthy people compared to

those of lesser means (see Exhibit 1 on

the previous page).

Buttressing the Harvard study’s analysis

is the UBS Investor Watch (April 2018)

that reveals 53% of the world’s wealthy

people believe they will live to be 100.

The study states, “A full 91% of U.S.

investors believe their wealth enables

them to live a healthier life, in line with

92% of investors globally. In fact, the very

wealthiest investors expect to live the

longest—and they are the most willing to

sacrifice wealth for better health.”

(Source: https://www.ubs.com/us/en/wealth/

news/wealth-management-americas-news

.html/en/2018/04/19/americas-financial-

changes.html)

This gives a wealthy individual’s PPVUL-

longevity profile a longer runway for

accelerated, tax-free growth and income

(as long as the policy remains in force

until the insured dies) but an equally

long runway for an insurance company

to raise policy costs under the non-

guaranteed scenario (i.e. up to the

policy’s filed and guaranteed charges).

A Fiduciary’s A Fiduciary’s A Fiduciary’s A Fiduciary’s Scenario AnalysisScenario AnalysisScenario AnalysisScenario Analysis

A wealth advisor, therefore, assessing a

PPVUL policy’s long-term viability,

considers various possibilities for both

the portfolio’s rate of return and the

policy’s costs. As it is with any

Illustration Games


8

investment evaluation, return and costs

must be modeled with equal emphasis.

A PPVUL policy’s rate of

return assumption is the

result of the portfolio’s asset

allocation and investment

choices, just like other

portfolio types such as

taxable, retirement, and

trusts.

The cost analysis assumption

must include scenarios

between two endpoints: 1)

the current or non-guaranteed charges

that represent the “best-case” scenario

and 2) the guaranteed charges that are

the insurance company’s contractual

obligation (or the “worst-case” scenario).

This is precisely the evaluation the NAIC

and FINRA regulations expect.

Here is the prudent due diligence path:

A wealth advisor is assured of a policy’s

viability to the insured’s death if the

considered return scenarios support the

policy’s guaranteed costs (less any

withdrawals) for the longevity profile

indicated in Exhibit 1 plusplusplusplus any buffer

based on the insured’s family history

that may suggest an even longer

lifespan, even to ages greater than 100.

This reveals a simple profit/loss model.

Cash inflows (premium deposits and portfolio growth)

MMMMinusinusinusinus

Cash outflows (guaranteed policy costs and withdrawals)

Risk management is one of a wealth

advisor’s key client services (see

“Bridging from Investment Risk to

Stability”. Regarding PPVUL,

the main area beyond an

advisor’s influence is the

insurance company’s future

operational and cost

choices. By using

guaranteed charges as the

baseline, the advisor

effectively eliminates an

entire risk category related

to the policy’s profit

equation (i.e. unexpected

policy costs increased at the insurance

company’s discretion).

Unfortunately for common PPVUL policy

types (i.e. other than Great-West’s

design with guaranteed policy costs as

the only path), to have an insurance

consultant/agent emphasize higher

guaranteed charges compared to the

lower - but less dependable - current

charges is not a recipe for sales success.

Policy MaintenancePolicy MaintenancePolicy MaintenancePolicy Maintenance or or or or Suffer Suffer Suffer Suffer

Increased Increased Increased Increased Lapse Lapse Lapse Lapse RiskRiskRiskRisk

Policies that have positive net cash flow

deliver death benefits throughout the

age sequence even past age 100;

policies with negative cash flows

eventually collapse, with the invested

premium essentially wasted. And, if

loans were taken out against a PPVUL

policy’s cash value, upon lapse, the loan

amount is taxed (i.e. what is called a

“phantom tax” because a tax obligation

Illustration Games


9

exists but without sufficient

compensating income to pay for it).

PPVUL policies must also comply with

laws governing the interaction between

portfolio return and policy costs; these

laws legally define insurance (known as

Section 7202). The legal basis mandates

that the investment/cash value and

death benefit relationship stay within a

certain range (or corridor) defined by

two actuarial tests (the details of which

are beyond this whitepaper’s scope). If

outside the range, the policy is no longer

defined as insurance.

Unlike the Great-West product that has

built-in 7702 compliance (and no lapse

risk caused by unforeseen policy-cost

increases), other insurance companies

rigorously manage this corridor to avoid

the catastrophe of a non-compliant

policy. Lacking intentional advisor/agent

adjustments for common PPVUL policy

designs – adding extra premium or

reducing the death benefit – the policy

will often lapse even before the insured’s

target actuarial mortality.

Therefore, both the NAIC- and FINRA-

regulated Illustration structures intend

to bring visibility to the stresses on

policies caused by lower real portfolio

returns (e.g. 0% return) and higher policy

costs up to a policy’s filed guaranteed

charges.

Guaranteed policy charges are forced

into life insurance Illustrations for the

acknowledged probability that the

insurance company may choose to or be

financially forced to charge the policy

owner more than their good intentions

may suggest (i.e. those intentions

reflected in non-guaranteed current

charges). In fact, in recent years a

number of instances have emerged in

which companies unilaterally increased

life insurance charges (see Law360, 2016:

“The Price of Mortality: Cost-Of-Life-Insurance

Cases”; Forbes, 2017: “A Problem with Life

Insurance That’s Universal”; New York Times,

2016: “Rising Premiums for Universal Life

Insurance Draw Scrutiny”; Wall Street Journal,

2015: “Surprise: Your Life-Insurance Rates Are

Going Up”; Wall Street Journal, 2014: “Scrutiny of

Stock-Linked Insurance Policies Grows”)

Without an advisor’s policy maintenance,

an insurance company’s discretionary

cost increases may erode a policy’s long-

term viability leading to possible lapse

and its devastating financial

consequences.

Illustration Games


10

Uncovering Uncovering Uncovering Uncovering PPVUL PPVUL PPVUL PPVUL Illustration Illustration Illustration Illustration

Games Games Games Games

The selling process for any product

amplifies advantages and diminishes

disadvantages. The difference with life

insurance sales is the NAIC and FINRA

directives guide a balanced

presentation. With a policy’s decades-

long profile, a misrepresented

presentation may lead to a failed policy,

an outcome that can have substantial

long-term implications even to

downstream generations.

An agent offering a less-than-

competitive policy has the regulatory

spotlight shining on the policy’s problem

areas. To combat negative reactions

from wealth advisors, sales people may

engage in tactics that put important

issues in the shadows, what are called

here “illustration games”.

The following analysis uses actual sales

presentation excerpts (with identifiers

redacted) from insurance

agents/consultants offering one or more

insurance companies’ common PPVUL

policy designs.

Illustration Illustration Illustration Illustration Game #1: Game #1: Game #1: Game #1: The PreThe PreThe PreThe Pre----

Application IllustrationApplication IllustrationApplication IllustrationApplication Illustration

Exhibit 2 shows a common tactic to get a

wealth advisor and/or prospective policy

owner excited about PPVUL’s financial

and wealth benefits using a non-

compliant, best-case model only. The

sales tactic moves the decision forward

with the non-compliant model and then

includes the required Illustration in the

final application package (where it can

be mixed in for less exposure with many

other financial and medical underwriting

documents).

Exhibit 2

Illustration Games


11

Notice that this pre-application model

excludes guaranteed charges compared

to the mandated Illustration.

Illustration Illustration Illustration Illustration Game #2: Game #2: Game #2: Game #2: High High High High and and and and Level Level Level Level

Rates of ReturnRates of ReturnRates of ReturnRates of Return

With the FINRA rules, two return

comparison points are required: 0% and

another that must be less than or equal

to 12%. Most illustrations presented by

insurance consultants/agents, for the

flexible return option, enter the higher

range of the allowable upper boundary

such as 10%.

This presents two substantial issues with

common PPVUL policies:

• Poor and Inconsistent IDF Poor and Inconsistent IDF Poor and Inconsistent IDF Poor and Inconsistent IDF

PPPPerformance. erformance. erformance. erformance. Unless the investment

options are open architecture (e.g.

ETFs, mutual funds, hedge funds,

private equity, etc. as with the Great-

West PPVUL policy design), the

traditional insurance dedicated fund

(“IDF”) choices offered through

platform providers linked to common

PPVUL policies are unlikely to achieve

even half the upper range (i.e. 6%).

The reason is the persistently poor

performance for the vast majority of

IDFs (see “Obsolete IDFs”).

• Not a Fiduciary Portfolio. Not a Fiduciary Portfolio. Not a Fiduciary Portfolio. Not a Fiduciary Portfolio. Typical

PPVUL portfolios use the Internal

Revenue Code 817(h) diversification

laws’ “look-through” rule that allows a

single IDF to fulfill the safe-harbor

diversification requirements (i.e. a

minimum of five investment in which

no one investment can be >55%; no

two >70%, no three >80%; no four

>90%).

This means that, while compliant to

the diversification law, PPVUL

portfolios are often undiversified and

exposed to investment-strategy-

specific risks. Such an exposure is

eliminated when using an advisor’s

built, managed, and monitored

portfolio using the advisory firm’s

preferred investments and supported

with well-considered diversification

principles according to a targeted

investment objective. (See “Client

Value Proposition”)

Both the NAIC and FINRA permit a

level-return scenario. While this

distorts the reality of a portfolio’s true

experience with market fluctuations,

it’s a practical position given the only

other option would be to legislate the

This means that, while compliant to the diversification law, PPVUL portfolios are often

undiversified and exposed to investment-strategy-specific risks. Such an exposure is

eliminated when using an advisor’s built, managed, and monitored portfolio using the

advisory firm’s preferred investments and supported with well-considered diversification

principles according to a targeted investment objective.

Illustration Games


12

use of actual historical returns for

some designated index or blend.

Given this accommodation against a

portfolio’s reality, it’s a much more

defensible position with a level-return

method to use a more realistic average

return such as 5% to 7% instead of

higher assumptions from 10% to 12%.

Illustration Illustration Illustration Illustration Game #3: Game #3: Game #3: Game #3: Not Showing the Not Showing the Not Showing the Not Showing the

0% Return Scenario0% Return Scenario0% Return Scenario0% Return Scenario

Insurance advisors may present the

guaranteed charges, but not the FINRA-

required 0% worst case. Many

practitioners misinterpret the purpose

of this cash-flow analysis.

The 0% return is not to suggest that this

year-over-year return for the policy’s life

could occur (what would otherwise be a

national economic catastrophe), but it

highlights the policy’s internal cost

efficiency.

In other words, the more a policy’s costs

overwhelm the death benefit calculation,

the sooner the policy will collapse. (The

Great-West policy’s costs are

guaranteed in a single, asset-based

charge that rises and falls with the

policy’s cash value; this enables the

policy to not lapse even in a 0% scenario

regardless of age (and assuming no

withdrawals).)

The native implication is insurance

companies, unable to show a sustained

death benefit, will be more likely to

increase current charges at some future

point than a carrier with an efficient

policy design (i.e. one that sustains a

death benefit across an insured’s entire

mortality horizon even at a 0% return

assumption).

Exhibit 3

Illustration Games


13

Illustration Game #Illustration Game #Illustration Game #Illustration Game #4: Non4: Non4: Non4: Non----Transparent Transparent Transparent Transparent

FeesFeesFeesFees

Every dollar of additional fees degrades

the policy’s tax-free compounding

(assuming the policy is held until the

policy owner’s death). Best practices in

any investing scenario avoids

unnecessary charges that do not

provide specific benefits to the portfolio.

In common PPVUL policies, there’s a

need for ongoing maintenance by an

insurance professional to keep the

policy from falling outside the expected

cash value-to-death benefit corridor

necessary to keep it compliant with

insurance definitions (see the above

section “Policy Maintenance or Suffer

Increased Lapse Risk” on page XX).

It is reasonable to compensate an agent

for this ongoing maintenance and

minimize lapse risk. (Note: Great-West’s

policy, as a no-maintenance design,

complies with formal corridor tests

defining insurance.)

However, this maintenance work is

minimal and annual. Some insurance

companies have negotiated annual

maintenance fees with agents of 85

basis points, which is an excessive

amount for the average of one to two

hours required each year (with some

years needing no work and others more

when a premium or death benefit

adjustment is needed).

Consider a policy with a cash value of $1

million, this would equal $8,500; a $10

million policy would be $85,000. These

are exorbitant hour-equivalent charges.

Broker/dealers or broker/general agents

may engineer additional fees for agent

oversight (i.e. as much as 25 basis points

per year). Again, this is not to say there

isn’t work to be done, but the actual

oversight effort is low for the amount

charged.

When fees are high, especially compared

to the required guaranteed-charge

scenario, other creative approaches

emerge to entice investors and/or their

wealth advisors. A recent case showed

an agent offering “top-client” fee credits

to lower the stated charges but without

disclosing that these offsets were fully

discretionary.

Illustrations take these extra charges

and embed them into the insurance

company’s Mortality & Expense fee. This

lack of transparency keeps a policy

owner or advisor from identifying the

higher costs for the work required

compared to a case that doesn’t have

agent and broker/dealer compensation.

(Typically, only an expert insurance

analyst would be able to uncover the

excessive fees from the state-filed

insurance charges.)

Illustration Games


14

Regulations Have a PurposeRegulations Have a PurposeRegulations Have a PurposeRegulations Have a Purpose

The NAIC and FINRA Illustration

regulations produce a set of scenarios

that would not appear if left solely to a

marketing presentation. This gives a

clear-minded and diligent advisor the

opportunity to evaluate a life insurance

policy’s viability for a client’s particular

long-term needs.

To this point, an Illustration’s depiction of

multiple scenarios (i.e. guaranteed

charges vs. non-guaranteed vs. assumed

rates of return) recognizes that a policy’s

potentially long duration may not only

outlast an insurance company’s current

strategies, operations, and financial

capabilities but also a family’s

relationship with its advisor and/or

insurance agent.

Therefore, an advisor that may not be in

an advisory role with the family in the

future is still tasked as a fiduciary – in the

present time – to judge a policy’s viability

across the insured’s mortality horizon.

And, this fiduciary orientation should

lead advisors to evaluate an expanded

array of PPVUL policy designs not just

one offered by a friendly insurance

agent or consultant. Doing so will bring

to the forefront important innovations

that have been made in advisor-focused

life insurance products such as the

unique Great-West PPVUL offering.

An objective of informed decision

making is behind the NAIC/FINRA

regulations. And what a choice PPVUL is

for a family’s investment plan: tax-free

income; tax-free growth; tax-free death

benefit (as long as the policy is held until

the insured dies); use preferred

investments; integrate in the wealth

plan; create wealth for downstream

generations and charitable passions.

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15

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to buy or sell any security or other financial instrument.

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For more information contact:

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