Job Details

Position Summary

Compliance Counsel is responsible for developing a comprehensive understanding of the Compliance Department operations, with the potential of overseeing and managing the Compliance Department. Managing and overseeing compliance activities for all states in which the company operates. Responsibilities also include providing compliance direction to licensed attorneys and other legal professionals, promptly identifying and implementing new compliance requirements as they arise, maintaining FSL's regulatory compliance for its insurance products and services sold through appropriately licensed agents and administrators, and other duties as may be assigned.

Expectations

Individual shall timely perform legislative reviews and monitoring of all laws and regulatory changes that impact compliance and procedures for the products and services provided by company and its affiliates and promptly communicate all such applicable updates to affected departments. Examples include, but are not limited to, Health Care Reform, mandated benefits, annuity/senior suitability, state prompt pay/claims settlement practices/appeal procedures, state guarantee association notices, state complaint notification requirements, minimum health standards laws, life insurance replacement, interest on death proceeds, and agent and administrator requirements.

• Anti – Money Laundering. Responsibilities include maintaining AML procedures, coordinating with accounting, claims and customer service departments, agent communications including standards of payment, red flags, producer's guide, verification of prior AML training, coordination with human resources department for the AML training for home office personnel, and coordination of annual AML testing requirements. Duties also include assuring AML compliance of individual cash value life and annuity products, periodic review and update of corporate AML policy and procedures, coordination of annual AML testing with corporate Audit, as well as coordination and documentation of periodic SDN and FinCEN searches with IT department.
• Standard Practice Memorandums (SPM) and Compliance Bulletins. Research and update SPMs to incorporate legislative changes. Draft and coordinate distribution of compliance bulletins.
• Product Evaluation. Assist marketing and product control in the evaluation of new products/ideas and identify regulatory and filing issues that may impact the programs.
• Life/annuity/financial product line compliance. Includes legal support and assistance to (i) marketing and product control for new product analysis and development, and (ii) contracts department for existing product updates, new product contract drafting and project implementation, and objections on product filings.
• NAIC Best Interest Annuity Suitability Compliance. – Review and recommend updates to NAIC Best Interest Annuity Suitability and related state Supervision System including: (i) Procedures to inform producers of the Best Interest rules requirements; (ii) Producer training manuals/materials/ and communications; (iii) Product specific promotional materials and agent training; (iv) New business process to assure all applicable forms and suitability review completed prior to issue; (v) Procedures to review recommendations; (vi) Annual reporting to states and senior management.
• Advertising Review and Marketing Compliance Support. Assist marketing department with developing agent training, client presentations and advanced markets sales concepts, advertising and website review, and recommendations and approval for regulatory compliance.
• Policy Filing Support. Provide assistance to the contracts department when requested. Monitor and communicate changes to policy form and rate filing requirements and procedures in the various states.
• Claims Support. Research and respond to claims questions regarding mandated benefits, prompt pay statutes, interest, subrogation, etc.
• Market Conduct. Review and evaluation of market conduct issues when requested.
• General Regulatory Compliance. – Provide legal support and guidance regarding the following: (i) Life Underwriting developments including genetic information, AIDs, Search Engines; (ii) NAIC Lost Policyholder reporting; (iii) Life Claims questions related to prompt pay, interest, child support, rescissions; (iv) Licensing appointment, policies and procedures, controls and producer oversight; (v) Assist with Periodic Reporting.

Competencies

• Strong management skills.
• Exceptional verbal and written communication, interpersonal, problem-solving, analytical, oral presentation, and organizational skills.

Requisites

• Juris Doctor and attendant Bachelor of Arts or Bachelor of Science degrees.
• 7+ years of industry experience in annuities and interest sensitive life products.
• 3+ years of management experience (functional and personnel).