CLHIA Standardized Advisor Practice Review for Use in the MGA channelRelease Date: 08/21/2017 Staff Reference: Justin Glinski
The Standardized Advisor Practice Review for Use in the MGA Channel (APR) is a standardized survey template that complements the CLHIA Reference Document Insurer Systems for Monitoring Statutory Compliance of Advisors. The APR is intended to assist in the ongoing assessment of advisor compliance in the MGA channel.
This survey will be reviewed and updated on an as-needed basis to reflect changes in industry practices, new statutory requirements and interpretations with respect to the applicability of existing statutory requirements.
Use by the Company
Companies should check the CLHIA website to confirm that the current version is being used.
If a Company does not wish to receive a response to a specific question or group of questions, the Company may mark “Not Applicable” in the answer field.
Apart from adding “Not Applicable” in the answer field, the questions in Sections 1 cannot be added to or otherwise modified.
If a Company wishes to ask additional questions, these should be added in Section 2. Similarly, Companies should conduct random checks of advisor files to confirm they have adequate documentation related to the required disclosures and evidence of needs-based sales practices, including a fact find, written needs-analysis and “reason-why” letter.
Use by the advisor
Some of the questions can be answered with checks or filling in blanks. Many of the questions require brief written descriptions of policies or procedures or attachments.
It is generally assumed that advisors will have written policies and procedures that address the matters covered in this survey and should submit copies of such with their responses.
Where the advisor has a comprehensive set of up-to-date written policies and procedures, it will generally be sufficient to attach these and note beside each question in the APR the relevant section in the policies and procedures that addresses the question. Where the advisor does not have written policies and procedures or the policies and procedures do not address the specific question, a written description of relevant practices should be provided in the response.
Generally, there are no “correct” answers. An advisor’s response to a specific question will be interpreted within the context of the advisor’s overall practices and the Company’s expectations regarding compliance practices.
If gaps are identified, there is an expectation that Companies and advisors will work together to develop a remediation plan to close the gaps.