Financial Institution Status?

As many of you know, we have been closely monitoring the DOL situation and how it will affect our industry, our reps and our standing as an IMO. We have been diligently working with industry experts to prepare for what is coming in 2017. Working closely with our Partners in IDA, as well as some of our Synergy Partners, we have a real plan of action no matter what direction we need to go in. No matter what direction YOU need to go in.

Our biggest idea that we can bring to you is this- don’t panic! There is no one in our industry who can tell you with any certainty exactly what will happen and what is needed for preparing for the New Post DOL world. There are just more questions. Even with the release of the DOL Q & A last week, we still don’t have definitive answers. Be patient. Keep your head up and listen to people who you trust. Now is not the time to jump ship based on here say. Stay the course. This is my advise.

Here is some more interesting advise from Sheryl Moore- noted expert in the annuity world.


October 31, 2016 by Sheryl J. Moore

Dozens of Field Marketing Organizations (FMOs) and Brokerage General Agencies (BGAs) have been contacting me since the Department of Labor’s (DOL’s) final fiduciary rule was issued; wanting to know how they too can apply to become a ‘Financial Institution.’ In response, I reached back out to my folks at the DOL, asking for their guidance. In the interim, the 18 marketing organizations that have “applied with the DOL to be a Financial Institution (FI)” have received much press…many of these firms are even recruiting to this.

Today, I finally caught up with a lawyer I’ve been working with at the DOL. Interestingly, he indicates that there is no need for any marketing group or agency to submit an application for FI status. Although the DOL has received 18 applications thus far, it is unnecessary to apply. Ultimately, the DOL will issue an exemption, and if an FMO or BGA complies with the exemption, they will have relief. All one needs to do is notify the agency that they intend to comply with the class exemption.

Now, that being said, the DOL welcomes the conversations that they are having with marketing groups and agencies. However, the DOL’s intent is to provide a larger form of exempted relief, and all a firm needs to do is meet the exemptions.

This attorney could not speak to the date, upon which, such relief may be issued. However, he assured me that it is forthcoming.

So, if your marketing group or agency is tired of hearing from your reps that they are concerned you haven’t applied for FI status…just explain that you don’t need to.

About Jeffrey Berson

40 years in and around the industry has made Insurance a part of my DNA. I have had the pleasure of working with and for some of the greatest minds in our industry. My "Bersonal" View is an attempt to capture some of the best ideas, the best concepts and the best practices in a way that can lead to success for others. It will certainly be my point of view, so please...don't take it "Bersonal".
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1 Response to Financial Institution Status?

  1. Ben ward says:

    Thanks Jeffery

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