1. So You Think You Know the Fiduciary Rule? July 12, 2016 12:00 - 1:00 p.m. (EDT) Guest Speaker: Marcia S. Wagner Principal The Wagner Law Group Hosted by: Alison Salka Senior Vice President and Director of Research LIMRA Please email questions to ddupont@limra.comddupont@limra.com

2. LIMRA SECURE RETIREMENT INSTITUTE Question 1 I hear two things in the market place - the first is that PTE 84-24 governs first and foremost with respect to the fiduciary rule and fixed annuities. The second is if you're dealing with qualified money then the fiduciary rules apply first and foremost. Even if you're recommending a fixed annuity (a MYGA, for example) within the qualified space, you are a fiduciary and subject to the BICE and all other applicable rules and requirements. Which is it?

3. LIMRA SECURE RETIREMENT INSTITUTE Question 2 How are firms handling compensation and incentives like trips and bonuses given the new rule? Do you think we can still incent on financial services sales in the future?

4. LIMRA SECURE RETIREMENT INSTITUTE Question 3 How can we make the case under BICE that life insurance commissions do not result in biased advice when, as a percentage of premium, they are typically 20-30x what an annuity or mutual fund commission would be?

5. LIMRA SECURE RETIREMENT INSTITUTE Question 4 I am curious to know whether there are standard disclosure and consent forms being created or proposed for use for companies that have to adhere to the BICE standards and for companies that have to adhere to the Impartial Conduct Standards?

6. LIMRA SECURE RETIREMENT INSTITUTE Question 5 As a captive carrier only selling fixed annuities (no indexed) how do we: - ensure our contract is in the best interest of the client? - best utilize PTE 84-24? Also, how will the sale of life insurance be impacted - for example, if we use RMDs to fund a WL policy, is this a fiduciary act and what disclosures need to be given at time of sale of the WL?

7. LIMRA SECURE RETIREMENT INSTITUTE Question 6 Would the sale of a variable universal life policy in connection with a recommendation to distribute funds from an IRA plan fall under the BIC Exemption or PTE 84-24? If a recommendation was made in the past to distribute funds from an IRA to purchase life insurance with annual proceeds and scheduled distributions are coming up in 2017 and 2018, would the existing plan fall under the new fiduciary rules?

8. LIMRA SECURE RETIREMENT INSTITUTE Questions 7 Would you consider one RIA referring a client to another RIA (within the same RIA) to get either a rollover recommendation for a individual or record-keeper recommendation for a plan sponsor a "fiduciary act" within the Referral part of the rule? OR since they are in the same RIA is it NOT a "fiduciary act" - it's just one RIA pointing the client to the other RIA within the RIA that handles that kind of business.

9. LIMRA SECURE RETIREMENT INSTITUTE Questions 8 For the small plan market; do you see B/Ds that are looking to use the BICE creating a process within the home office to generate the documented process to determine that a sale is in the best interest of the client? Or are they providing a software tool to the field force to generate that documentation on their own in the field?

10. LIMRA SECURE RETIREMENT INSTITUTE Question 9 Does the new Fiduciary rule apply to Non ERISA 403b plans? Specifically the K-12 market?

11. LIMRA SECURE RETIREMENT INSTITUTE Question 10 Regarding the sale of fixed annuities via both licensed bankers and Series 7 financial advisers.... do traditional MYGA fixed products fall under the DOL rules? Are they in reality or perceived to be less risk by regulators?

12. LIMRA SECURE RETIREMENT INSTITUTE Question 11 The Best Interest standard is clearly one in which a financial institution (1) eliminates as many conflicts with the client as possible and mitigates and then discloses the remaining conflicts under the BICE, as well as (2) looks for expense reductions and only offers reasonable cost investment products to the client. BUT... what ELSE should a firm be supervising to? A B-D has a ton of Regulatory Notices and FINRA Suitability Rule 2111.... but what else should a firm be supervising for BICE clients???

13. LIMRA SECURE RETIREMENT INSTITUTE Question 12 12b1's - can a Registered Rep sell a plan that has A Shares?

14. LIMRA SECURE RETIREMENT INSTITUTE QUESTIONS FOR Marcia Wagner Have a question you would like our Presenter Marcia Wagner to Answer? Please email Deb Dupont @ ddupont@limra.comddupont@limra.com