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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.