Download COMPLIANCE TEAM OUTLINE

TEMPLATE 1
COMPLIANCE TEAM OUTLINE
Structure
The recommended Compliance Team (Compliance Committee, Market Conduct Team,
or whatever your company chooses to name it) should meet regularly, at a minimum of
once each quarter. The Team is cross-functional, and should include these
representatives:
Compliance officer/General Counsel
IMSA coordinator
Advertising review - primary responsible person
Licensing Manager
Complaints Manager
Head Underwriter
Marketing Manager(s)
Auditor
SIU Manager
Customer Service Manager
Training Manager
Human Resources
Input
The information which should be regularly available to the Team members includes but
is not limited to:
Complaint reports (sorted at least by agent, agency, product type, complaint type) and t
trend analysis
Customer survey reports and analysis
Results of any focus groups or special surveys
Legal review monitoring problems
Replacement activity (sorted at least by agent, agency, product type) and analysis
Non-disclosed replacement trends (as discovered through customer surveys and policyservice requests such as loans, rollovers, reduced paid-up, reduced term,
surrenders, etc.)
Customer Transaction reports by agent : surrenders/withdrawals/not taken
Lapse trends by agent
Internal Compliance Audit results and recommendations
Underwriting exception reports, by agent
Licensing exception reports, by agency or recruiter
Advertising rejection reports, by agent
Disciplinary actions or investigations
Informal, anecdotal concerns
Output
The purpose of this Team will be to review available information and determine at least
the following:
1. Recommendations for changes in training or policies and procedures throughout the
functional areas impacted by IMSA.
2. Recognition of ‘red flags’ for particular agents or agencies, and recommendations to
the appropriate department for disciplinary action.
3. Recommendations for additional types of information to be made available for the
Team.
4. Reports and recommendations to Senior Management concerning the adequacy of
the company’s ethical market conduct activities.