This is not what effective disclosure looks like.
Much of today was spent in preparation for my presentation at the New England Chapter E-day, to be held on Wednesday of this week: June 12, 2019. My topic is the confusing array of disclosures that are now required in NY, especially with the addition of Regulation 187. The confusion is a result of the proliferation of regulations that, no doubt have good intentions, but for my money, are likely to leave consumers more confused than empowered. I only have an hour in my E-day session and I don’t think I can cover all the overlapping disclosure requirements in Section 3209, Reg 60, Reg 74, Reg 187, Reg 194, and Reg 210. If I can't do that -just explain what they are- how is an agent going to be able to explain to a consumer what each of them are and why the numbers and terms are different when they are talking about essentially the same thing? I am all on board that consumers should know what they are buying and from whom. I agree that producers should have an in-depth knowledge of the insurance products they sell. Bait and switch is bad, as are commission-driven sales. Misleading consumers into replacing good products with the latest shiny new object is not tolerable.
But working through all the disclosure requirements today, I don’t think this matrix of regulations gets consumers to a better place. Because information is presented in so many different ways, they will have more information for sure. But will it make sense to anyone?
I haven’t yet seen a package of these disclosures prepared for a real sale. I hope to soon. I hope it is more clear than it appears it will be from going through all these regulations. For the consumers of insurance products in NY, I hope I am wrong. I would love your thoughts on this. My presentation will be posted in our Suitability and Standard of Care Center for E-day attendees and Center members after the event. There is a members-only forum to discuss compliance strategies. Take advantage of the opportunity to network on these challenging issues.
At least there was this…