The New York State Department of Financial Services (NY DFS) has released the final version of Best-Interests Regulation 187 (NY 187). The final regulation, now called “Suitability and Best Interests in Life Insurance and Annuity Transactions,” will require producers and insurers to implement a process that ensures they’re acting in the consumer’s best interest when recommending an annuity or life insurance policy issued in New York. The new regulations, which went into effect for annuity products in 2019, will take effect on February 1, 2020, for life insurance policies. Learn more

NY Regulation 187 Requirements

What this means for you

If you sell New York life insurance, you will now be required to complete two types of training prior to soliciting business in New York:

1. NY 187 Best-Interests Training – This is a one-time training requirement for both annuities and life insurance. If you've taken the combined Life Insurance and Annuity Transactions course, you don't need to take it again to sell life insurance. If not, you'll need to take this training before the application is signed for any carrier's New York life insurance product.
2. Carrier-specific Product Training – In order to sell life insurance with Lincoln (fixed individual, variable individual and MoneyGuard products), you will now be required to take product training.

You will also need to go through suitability review prior to policy issue. This includes:

1. Disclosure requirements at the time of sale regarding suitability and product information, including product features, benefits and costs.
2. Producer documentation requirements regarding the basis for any recommendation.
3. Suitability review by your back office or the carrier must be conducted and approved for all cases prior to policy issue.

Key tips and dates

• For cases signed on or after February 1, 2020, New York requires Regulation 187 Best Interests and product training to be taken prior to soliciting the Life or MoneyGuard application.
• Prior to completing Best-Interests training, you should consult your back office for an approved vendor list and any additional firm-specific requirements.
• If you took an Annuity Transactions-only course, you will be required to complete a course for Life Insurance Transactions prior to submitting New York business signed on or after February 1, 2020.
• The Life Suitability, Best Interest and Summary Disclosure Form LF11943NY will need to be completed and submitted with the application if your back office isn't conducting the suitability review.
• If the application is signed prior to February 1, 2020 AND submitted to Lincoln in-good-order no later than February 28, 2020, the NY Regulation 187 Best Interests training is NOT required for that case.

Presale Requirement 1: NY Regulation 187 Best-Interests Training

Please note: some vendors may not offer a combined Life and Annuity Transaction course, and therefore, separate courses will be required.

Presale Requirement 2: Lincoln Life Product Training