NGL Annual Compliance Notice 2018

NGL values the business relationship it has with you. As partners in business we want to protect all parties from potential liabilities that may arise due to noncompliance with laws and regulations. In the agreement you have with NGL, you are required to comply with federal and state laws related to our business. The purpose of this communication is to remind you of the responsibilities under the agreements we have in place. We also want to remind you to review NGL’s Compliance Manual. Please understand we did not create an all-inclusive list but intended to cover the primary areas of compliance concern.

Your responsibilities include:

  • Overall compliance with federal, state or local laws, rules and regulations where you are doing business. This includes:
    • Appropriate protection of client information, including personal health information, personally identifiable information (SS#) and personal financial information;
    • Compliance with NGL’s privacy policies and practices, as well as state and federal HIPAA, HITECH and Gramm-Leach Bliley requirements including proper encryption of data and business continuation policies;
    • Compliance with NGL’s data security requirements, including document storage, building security/access and document retention;
    • Compliance with newly/soon-to-be enacted data protection laws (such as the NY Cybersecurity Regulations and NAIC Data Security Model Law) that may affect your business operations. Additional information of these laws can be found here and here.
    • Compliance with the Federal Wiretap laws
    • Compliance with applicable Annuity Suitability regulations
    • Compliance with federal and state telemarketing rules and regulations.
      – Reminder: NGL does not currently allow outbound telephone solicitation unless authorized by express written permission by the consumer or through a prior business relationship as defined within the Telemarketing Consumer Protection Act (TCPA).
      – Auto-dialers, prerecorded messages, faxes and texting are not NGL approved methods of solicitation; email blasts should follow NGL’s advertising review process prior to use.
    • Compliance with state or federal disclosure requirements regarding the recording of telephone conversations
    • Compliance with state or federal disclosure requirements related to the sale of products to seniors
  • Adherence with NGL’s underwriting guidelines. Agents should seek guidance where necessary to ensure health questions are answered appropriately;
  • The monitoring and performance of agents/brokers through which you market NGL products; This includes:
    • Product training
    • Compliance with Anti-Money Laundering (AML) requirements
    • Compliance with NGL’s agent contracting and appointment requirements
    • Adherence to NGL’s Recruiting and Commission Guidelines
    • Compliance with the provisions outlined in NGL’s Compliance Manual
  • Obtaining NGL’s approval of all marketing materials prior to implementation. Agents and partners should work through NGL’s Marketing Department on requirements and the approval process
  • Compliance with the Department of Labor’s (DOL) Fiduciary Rule PTE 84-24 regarding the purchase of life insurance or an annuity with qualified funds. While the DOL has recently announced an 18-month extension of enforcement until July 1st, 2019, the use of the form is still recommended.
  • Duty to report to NGL:
    • Potential or filed litigation affecting NGL’s interests
  • Reporting to NGL any suspicious or fraudulent activity on the part of an agent or organization you are affiliated with.

We encourage you to review your agreement with NGL as well as NGL’s Compliance Manual. If you have any questions please call us at 608-257-5611, ext. 5790, or email Partner Compliance. If you have heard about a recent rule change that may impact our forms or policies please let us know.

We value our relationship with you and thank you for all of your efforts!
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