Annuity suitability review on every sale, before the contract is issued
Every annuity sale reviewed before issue, its reason on file.
See one case, screen by screen ↓Software that reviews each annuity recommendation before the contract is issued, to show there is a reasonable basis that it fits the buyer’s situation, needs and objectives. Annuity Suitability Review reads the whole sale file — including the producer’s notes — runs twelve best-interest checks with their rules and evidence, and holds issue when a blocking check fails.
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The best-interest rule says the carrier may not issue a recommended annuity without a reasonable basis that it fits the buyer’s financial situation, needs and objectives — and it must review each recommendation before issue. In practice the reviewer reads the suitability questionnaire, the disclosures and the producer’s written basis, and most sales pass on the form’s boxes.
The harm sits where nobody looks. The producer’s call notes and the source-of-funds detail are a separate file, and they often say something the questionnaire does not: a move, a roof, an entrance fee. The surrender charge is a percentage on the form, but the harm is a date — the year she needs the money against the year it comes free. Without that view, the unsuitable sale surfaces later, when the buyer or her daughter complains about a surrender charge.
Estimated split for one flagged sale that is returned to the producer, by hand and with the solution.
Six agents read every sale, weigh the surrender schedule against her cash needs and hold issue on a failed check; the reviewer decides.
Dorothy M. Kessler, 78, of Toledo, Ohio, is sold a $185,000 fixed indexed annuity with a ten-year surrender schedule. Here is what happens before Harborline Life & Annuity issues it, screen by screen, in the working solution.
Anita opens today’s sales: 68 applications since 07:00, each read in 7–9 seconds. 51 passed and were released to issue, each with its written record. 9 wait for a reviewer, 5 are back with the producer and 3 are escalated to Renee Okafor in compliance. The oldest flag is from 07:18.
“Every annuity application read on arrival — 68 since 07:00.”
Sale ASR-26-04417: Dorothy is widowed, rents in Toledo and has a daughter, Karen, in Dayton. Income $37,680 against expenses of $41,760 — short $4,080 a year. Liquid net worth $236,400, of which $185,000 goes into Harborline Summit 10, leaving $51,400. A red band runs across the top: issue held, two checks fail.
“Harborline will not issue this contract until a reviewer decides · Model #275 §6.C(1).”
The application, the suitability questionnaire, the Appendix A disclosure, the product disclosure, the buyer’s guide receipt, the source of funds and the producer’s call notes — read in 1.2 seconds. All 14 consumer-profile factors are filled, each from its page. Then the answers are compared across the file, and one contradiction is found.
A blank factor stays blank and becomes a finding. It is never filled by guessing.
Questionnaire answer 4a: “None anticipated during the surrender period.” Glen Varga’s call notes of 22 Sep: she wants to be near Karen, has paid a deposit at Maple Court Commons, expects to move in spring 2028 with an entrance fee of about $92,000, and her roof needs replacing next spring, about $18,000. Both places are marked, side by side with the written basis.
“The checker never decides which document is right. It shows both; the reviewer asks the producer.”
Ten contract years at the guaranteed floor, 0% credited. In year 2 she needs $96,080: $29,320 comes from money outside the annuity and $18,500 from the 10% free withdrawal. That leaves $48,260 locked behind a 9% surrender charge — $4,343 to reach it — and nothing left outside. The surrender period ends in Oct 2036, at 88.
The tester never assumes index credits above the floor, and never projects a need the buyer did not state.
Money she will need during the surrender period fails, and so does premium share of liquid net worth: 78.3% of $236,400, against Harborline’s 50% limit for buyers 75 and over. Three warn — the surrender period ends after 85, the income rider costs $2,128 a year with no income start date anywhere in the file, and the written basis is silent on the move. Seven pass. On the checks screen, each one shows its source, its threshold and whether it blocks issue.
The checker never approves a sale and never removes a hold.
Anita moves the premium to the guideline cap of $118,200 — 50% of her liquid net worth. The runway recomputes: every need covered, $0 locked, no check fails. It also shows something to ask about: only $40 would be left outside the annuity after the 2028 move. Switching to Summit 5 at the same premium does not help — the same money stays locked.
“Nothing here changes the application.”
Two items, each with the quoted evidence and its rule: the liquidity answer does not match the notes, and the premium leaves the 2028 move locked. The $118,200 alternative is in the note. Renee Okafor is copied, the answer is due Wed 14 Oct, and the written review record — 2 fail, 3 warn, 7 pass, kept until Oct 2031 — files when Anita sends.
“Drafted by the request writer from the two failed checks · nothing is sent until you send it.”
Anita could approve with the failed checks — but only by writing why the sale is in Mrs. Kessler’s interest and requesting a second signature from Renee Okafor in sales-practice compliance. Until Renee signs, issue stays held.
“Two blocking checks fail. Issuing needs your reason and a second signature from Renee Okafor, sales-practice compliance.”
Glen Varga: 4 findings in 11 sales, and the same one three times in 90 days — the questionnaire said “None anticipated” while his own notes described money the buyer would need. Edna Pruett, 81, in August (hip surgery and home care in 2027); Ruth Abernathy, 79, in September; Dorothy today. His training is current. One click asks his supervisor, Tom Whitcomb, for a review.
“Patterns for the producer supervisor, not discipline.”
The same sale, seen by the four people who carry it — what their week looked like, and what it looks like now.
Six agents read every sale, weigh the surrender schedule against her cash needs and hold issue on a failed check; the reviewer decides.
Reads the application, questionnaire, disclosures, source of funds and producer notes, and fills the 14 consumer-profile factors, each with the page it came from.
Compares every answer across the file — questionnaire, application, notes, source of funds — and flags contradictions and suspicious refusals to give profile information.
Takes every need the buyer stated, in any document, with its date, and pays it from money outside the annuity, then the free withdrawal — what is left is marked locked, with the charge to reach it.
Runs the twelve checks — care, disclosure, conflict of interest, documentation and Harborline guidelines — cites the rule and evidence for each, and holds issue when a blocking check fails.
Turns each failed check into one request — what is wrong, the evidence quoted, the rule, what would fix it — and writes the written review record.
Groups findings by producer, rule and week from the review records, and drafts the annual report to senior management.
Decides; an override needs compliance. The agents propose; a named person decides.
Reviewers and compliance can ask in plain words. Every answer cites the file, the contract, Model #275, the state rules or Harborline’s guidelines.
Why is Dorothy Kessler’s sale held?
Two checks fail. Her questionnaire says she needs none of the money during the surrender period, but Glen Varga’s notes of 22 Sep say she moves to Maple Court Commons in spring 2028 with an entrance fee of about $92,000. In contract year 2 that leaves $48,260 locked behind a 9% charge — $4,343 to reach it. The premium is also 78% of her liquid net worth, against the 50% limit for buyers 75+.
What premium would pass for Dorothy?
Up to $118,200 — 50% of her $236,400 liquid net worth. The roof and the 2028 entrance fee are then paid from money outside the annuity, and nothing she has said she needs is locked. It leaves only $40 outside after the move, so ask how she covers emergencies. Summit 5 at $185,000 does not help: the same $48,260 is still locked, at 6%.
Has Glen Varga had this finding before?
Twice in the last 90 days, the same pattern: “None anticipated” on the questionnaire, and money the buyer would need in his own notes — Edna Pruett in August and Ruth Abernathy in September. His training is current. A supervisor review is one click.
What must the annual supervision report contain?
A written report to senior management, including the head of audit, on a tested review of the supervision system, the exceptions found and the corrective action taken or recommended. The report page is built from the review records: 4,416 sales in Q3, 556 for a reviewer, findings by rule and the four corrective actions.
13 screens from the working solution, on its sample data. Pick one to see it large.
Every threshold the reviewer works to is a setting, saved as a draft and approved by sales-practice compliance.
| Setting | Default | Choose from |
|---|---|---|
| Senior review ages | Extra checks from 65; stricter guidelines from 75 | 60 · 65 · 70 · 75 · 80 |
| Premium share of liquid net worth (blocks issue) | 65% at 65–74 · 50% at 75+ | Per age band · Harborline guideline UG-4.2 |
| Warn when the surrender period ends after | Age 85 | 80 · 83 · 85 · 88 |
| Projection basis | 0% credited — the guaranteed floor | Free withdrawal per contract · rider fees shown separately |
| Liquidity check blocks issue | On | When any stated need is locked behind a surrender charge |
| Read producer notes against the questionnaire | On | Contradictions shown on both documents |
| Review clock | 1 hour to a reviewer’s desk · 1 business day to a decision | Flagged sale on a reviewer’s desk · decision |
| Record retention | 5 years | 5 · 7 · 10 years |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures: NAIC, Suitability in Annuity Transactions Model Regulation #275 (2020 revision) and implementation brief, Aug 2025 (49 jurisdictions); LIMRA, 2025 US individual annuity sales ($461.3B). People, producers, Harborline Life & Annuity and its Summit products named on this page are characters and sample data in the working solution.
Software that reviews each annuity recommendation before the contract is issued, to show there is a reasonable basis that it fits the buyer’s situation, needs and objectives. Annuity Suitability Review reads the whole sale file — including the producer’s notes — runs twelve best-interest checks with their rules and evidence, and holds issue when a blocking check fails.
It fills the 14 consumer-profile factors from the file, compares answers across documents, projects her stated cash needs against the surrender schedule, and runs checks grouped under care, disclosure, conflict of interest, documentation and your own guidelines. Each check names its source, such as a Model #275 section or guideline UG-4.2.
The liquidity tester takes every need she stated, in any document, with its date, and pays it first from money outside the annuity, then from the free withdrawal. Whatever is left is marked locked, with the charge to reach it. It uses the guaranteed floor only and never invents a need she did not state.
Yes. The producer’s call notes and written basis are read against the questionnaire, and a contradiction is marked on both documents. The profile checker never decides which is right; the reviewer asks the producer.
Only if the reviewer approves with an override: a written reason and a second signature from sales-practice compliance. Until then issue stays held. The agents can never release a hold.
Yes. The supervision report is built from the written review records — sales read by week, findings by rule, time to a decision and corrective action — and the supervision reporter drafts the annual report for compliance to complete and sign.
Yes. The agents read, compare, project and draft; the suitability reviewer passes, returns or escalates. The agents never approve a sale, never contact the buyer and never change the application, and nothing goes to the producer until the reviewer sends it.
The Agentic Solution Engine builds and deploys it from your requirements — your suitability guidelines, state rules, product schedules and a sample of past applications — and it goes live once every quality gate has passed. We will walk you through it on your own sales first.
Hundreds of record pages read before the underwriter opens the case.
1-min demoNew Business Case ManagementEvery open requirement chased, every case status known without a phone call.
1-min demoLife Underwriting Manual SearchImpairment ratings answered from the manual, with the page that says so.
1-min demoWe’ll run Annuity Suitability Review on a sample of your own recent applications.