Meet your survivor guides

1
(No Transcript)
2
Meet your survivor guides

• Keep your hands, arms and feet inside at all times

3
Caren Alvarado

• Assistance Vice President of Regulatory Affairs
  and Legal Fairmont Specialty
• Over 20 years of experience running compliance
  divisions for several large insurance companies
• Proud Mother of beautiful twin girls
• Loves to redline documents
• Tends to be passionate about all things
  compliance
• Enjoys finding creative solutions and thrives on
  a challenge

4
Ken Milhous

• President/Founder, Soseus LLC
• Over 14 Years experience developing marketing
  solutions
• Over 12 Years experience in travel insurance
  products
• Daddy of two charming kids and two lazy pugs
• Loves technology a bit too much
• Gravitates towards hazardous objects when
  mountain biking

5
Whats the big deal?

• If youre not scared, you should be

6
Compliance is key to success

• Compliance is good for brand
• Compliance is good for customers
• Compliance is good for business
• Compliance is good for our industry
• Compliance is good for everyone!

7
Insurance is under scrutiny

• We must evolve guidelines as regulation changes
• We must be proactive in discovering issues
• We must educate staff and partners
• We must stay one step ahead of regulators

8
Non-compliance is getting ugly

• License suspension/revocation
• Possible marketing restriction
• Fines and Legal Fees
• Negative Public Consent orders
• Penalties for agents
• On-site regulatory examinations
• Tarnished brand
• More intense regulations

9
What is advertising?

• Lets cover the basics, shall we?

10
How to spot advertising

• Marketing is any material or media that
  discusses, describes, depicts or portrays
  products or features
• Any material designed to promote, sell or induce
  the public to purchase, increase or modify an
  insurance policy

11
Obvious advertising samples

• Brochures and sales sheets
• Websites
• Radio and Television Commercials
• Publication ads
• Mailings
• Telemarketing scripts
• Invitation to Inquire

12
Less obvious advertising samples

• Material included with fulfillment to encourage
  renewal or buy-up
• Webcasts
• Prepared sales talks
• Social posts and blogs
• Lead Generations
• Newsletters
• Product comparisons

13
Is everything advertising?

• The distinction is based on the target audience
  and subject matter of material
• Non-advertising examples
• Internal communication
• Regular agent communication
• Customer communication that does not encourage
  coverage changes or additional purchase
• Material used to train and educate insurers
  employees or agents
• General announcement to group members regarding
  availability of a plan without a description

14
Your survivor checklist

• Dont forget this next part, theres gonna be a
  quiz

15
Are disclosures stated?

• Content must provide a fair and accurate
  description of exceptions, limitations and
  reductions
• Content not intended for public use, that could
  be misused, should be properly identified
• Content must clearly indicate the specific states
  the material is to be used in and/or states not
  approved

16
Is it fair accurate or misleading?

• No aspect of advertisement can be untrue,
  deceptive or misleading based on information
  included or omitted
• Products should be described as travel insurance
  policies and no alternate descriptors should be
  used
• Content cannot use uncommon insurance jargon
• Content cannot contain statements that describe
  benefits or attributes that do not exist
• Content cannot contain statements designed to
  disparage competitors
• Unfair or incomplete comparisons to other
  products prohibited

17
Does it contain deceptive messages?

• Content cannot contain words to exaggerate
  benefits beyond the terms of the policy all,
  full, complete, comprehensive
• Content cannot contain words with relative or
  misleading meaning free, no-cost, inexpensive,
  low cost
• Content cannot contain phrases that exaggerate
  insureds well-being worry-free, peace of mind,
  guaranteed
• Content cannot contain phrases that describe
  applicability of exceptions or reductions only,
  mere, just, minimum

18
Price Transparency

• There is increasing complexity within the travel
  industry
• This is an area of continuing evolution in the
  travel industry
• States are challenging the way the industry has
  always operated historically
• Travelers expect more information and choice
• Increased area of concern among regulators and
  the industry as a whole

19
Is it free of high-pressure tactics?

• Cannot use content that would induce purchase
  through force, fright or threat, explicit or
  implied
• Cannot use undue pressure to recommend the
  purchase of insurance
• Cannot communicate that bad things will happen if
  someone does not have insurance

20
Is the insurance type and insurer identified?

• An advertisement that fails to state clearly the
  type of insurance coverage being offered is
  prohibited
• The name of the actual insurer must be stated
• Any invitation to contract must include a form
  number of the policies advertised
• Any information regarding the companys ratings
  must be accurate and up to date
• Material cannot use a trade name, group
  designation, name of parent company, division of
  insurer, service mark, etc without disclosing the
  name of actual insurer

21
Is it free of opt out requirements?

• No acceptance by default allowed customers must
  not have to explicitly opt-out of a particular
  feature or service
• Mechanisms for allowing must be a opt-in
• Customers must make affirmative selection of
  insurance
• Opt Out insurance is illegal in the travel
  insurance industry
• Considered an unfair method of competition and
  deceptive insurance practice

22
Are endorsements compliant?

• Testimonials and endorsements must be genuine
• Content must represent the current opinion of the
  author
• Content must be applicable to the insurance
  marketed
• Content must be accurately reproduced
• Content must be current
• Statistics must be accurate and current and
  include cited sources

23
Game time!

• Whos gonna be voted off the island?

24
With our insurance you will ______

• have peace of mind.
• rest easier and vacation better.
• have some added comfort.

25
We can provide you ______

• with worry-free travel.
• travel with less worries.
• guaranteed safe travels.

26
When you travel ______

• things will go wrong.
• bad things will happen.
• the unexpected may happen.

27
Buy from us and get ______

• comprehensive coverage.
• a plan to help protect your needs.
• financial security.
• the extra protection you need.

28
We offer ______

• the biggest money-saver.
• affordable rates.
• rates that may be more affordable than you think.

29
Thanks for participating!

• You get to stay on the island.

30
Start with the basics

• Wax on, wax off soon youll be a black belt

31
Create a compliance checklist

• Define your compliance criteria and be sure to
  include
• Contact information
• Pricing
• Disclaimers/disclosures
• Product specifics
• Opt-in (not opt-out)
• Insurer/underwriter information
• Be sure to add your own compliance criteria

32
Website audit

• Schedule regular reviews to stay in compliance
• Keep record of high-risk pages
• Verify new content against checklist
• Tip Print each page and mark-up as reviewed to
  ensure no rock goes unturned
• Tip Create boilerplate messaging
• Tip Keep history of pages
• Tip Create matrix of type of content and pages

33
Caution pitfalls ahead

• Keep calm, well show you the way

34
Potential mobile pitfalls

• Reduced screen sizes mean less content
• Reduced screen sizes can hide or move content
• Difficult to read or access downloadable files
• Flipping between mobile and non-mobile pages

35
Potential social issues

• What if your post is shared (re-posted)? By an
  agent? By a consumer?
• Do your social messages include a method for
  viewing compliance information?
• What happens when a customer posts a review or
  compliant that includes inaccurate information?
• Remember that your post is out there forever!
• Is your Facebook page compliant?

36
Potential SEO/SEM issues

• META Tags
• Not easily reviewed difficult to audit
• Not updated often enough
• Text ads
• Limited messaging
• Possibly managed by third-party
• Banner ads
• Rotating messages
• No disclaimers

37
Other potential pitfalls

• What happens when a server goes offline?
• Do you need to be ADA (AODA) compliant?
• Do you have compliant desktop apps or mobile
  device apps?
• Are your outbound emails compliant?

38
What are we going to do!?

• Breathe deep.

39
Keep it simple!

• White space is your friend
• Simplify your message
• Less is more
• Create boilerplate messaging
• Create a single place for disclaimer information
  that can be used by social, email, ads, etc

40
Get creative

• Use this as an opportunity to refine your brand
  strategy and leverage new messaging that may be
  more effective
• Use compliant friendly questions like What kind
  of travel insurance are you looking for?
• Promote less-compliant touchy features like
  compare insurance plans or award-winning
  customer service
• Try capturing brand message using creative
  writing like Dont forget to pack your travel
  insurance
• Remember less copy may require less disclaimers
  and minimize your exposure

41
Track, review and document

• Schedule routine reviews
• Keep record of META information, ads, social
  history, etc
• Remove old online assets no longer in use
• Review ads with your ad manager
• Be ready for regulatory review

42
You survived!

• Questions? Email us!
• Caren Alvarado Caren.Alvarado_at_FairmontSpecialty.c
  om
• Ken Milhous kenm_at_soseus.com