Companion Group

Carrier appetite summary

Scope / entities - Manual applies to all members of "Companion Group": Companion Life Insurance Company, Niagara Life and Health Insurance Company, and Companion Life Insurance Company of California, collectively referred to as "the Group." It governs marketplace conduct for employees, independent producers (agents/brokers), MGAs/MGUs, TPAs and other partners that sell, underwrite, administer or service Group products. Preferred / target business - Producers and partners must only solicit and place approved Group products and benefits, in states where forms, rates and the producer’s license/appointment are active. - Group’s Accident & Health (A&H) Division serves as liaison with partners and expects effective controls over underwriting, premium and claims, with annual audits. Partners with Managing General Agent status are subject to an additional claims and underwriting audit each year. - Group encourages direct communication with Compliance and A&H for questions, early engagement on regulatory matters, and coordination on SERFF filings and product implementation. Restricted or declined practices / classes (conduct & compliance) - Unlicensed solicitation: absolutely prohibited. Producers may not solicit, take applications, or sell in any state without an active license and (when required) appointment in that state. - Sale of unapproved products or forms: prohibited. No product may be offered or sold until Compliance confirms state DOI approval of policies, certificates, applications/enrollment forms and associated rates. Producers/partners may not alter, add, or delete benefits or exclusions beyond what DOI and Group have approved. - Use of unapproved marketing/advertising: prohibited. All sales, marketing, illustrations (including software), quote sheets, internet/social media material, and videos that reference the Group or its products must be reviewed, stamped and logged as approved by Compliance before use. Materials may not be altered after approval. - Misrepresentation, twisting and churning: prohibited. Producers cannot misrepresent product terms, limitations or exclusions; all products must be clearly presented as insurance. Replacement of existing coverage is prohibited where not in the insured’s best interest, especially where done primarily to earn additional commissions (churning). - Rebating/inducements: prohibited in all states, regardless of state-specific allowance. Returning premium or commission or offering value-added services as an inducement to place business with the Group is not allowed. - Improper references to the Group’s parent company as a sales inducement: prohibited. - Providing tax or legal advice: prohibited. Producers and employees must direct customers to their own tax and legal advisors. - Unfair trade practices: any false, misleading, derogatory, or anti-competitive statements about competitors, their representatives or products are prohibited, whether or not specifically barred by state law. Geographic / regulatory notes - Group operates subject to each state’s Department of Insurance (DOI) rules. Manual repeatedly stresses that producers and partners must know and comply with all applicable state (and federal) requirements in any jurisdiction where they solicit or administer Group business. - Forms and rates are generally filed through SERFF; coverage and product availability may vary by state. Any internet or multi-jurisdictional advertising must clearly state that products may not be available in all states and should include effective dates for changeable information. - Market conduct examinations: multiple DOIs may examine the Group or its partners simultaneously. Partners must fully cooperate, provide organized responses within requested timeframes, and recognize that regulators treat partner actions as the Group’s own actions. Producer / broker requirements & duties - Licensing & appointment: - Group works exclusively through licensed independent agents and brokers; it does not employ its own agents. - Producers must be licensed as insurance producers in every state where they solicit Group business. - When allowed by law, the Group uses just-in-time appointment: appointment must occur within 15 days of a completed employer group application in a JIT state; in other states, appointment must be in place before solicitation or sale. - Continuing education & E&O: - Producers must complete all state-mandated CE and maintain proof of completion. - Producers must maintain errors and omissions coverage meeting Group requirements and provide current proof of coverage (e.g., certificate of insurance) immediately upon request. - Ongoing obligations to the Group: - Report within 15 days any regulatory action by a licensing state, felony conviction, lawsuit alleging producer misconduct, or revocation of appointment by another carrier. - Maintain documentation of policy and certificate deliveries (including employer delivery for group and association business) sufficient to evidence start of the free-look period; failure to do so may result in commission loss or termination. - Sales practice standards: - Use only Group-approved products and forms; describe products clearly, fairly, and in language customers understand; ensure product recommendations align with customer needs and objectives. - Verify customer identity; comply, where applicable, with Do Not Call rules and telemarketing restrictions including autodialed/prerecorded calls to wireless and residential numbers. - Never sign for customers, present blank forms for signature, or accept incomplete forms; all forms must be fully completed prior to signature. - Maintain privacy and security of customer health and nonpublic personal information in all formats; honor consumer privacy requests as required by law. Partner (MGA/MGU/TPA) expectations - All partners must maintain robust compliance with DOI rules, ensure business functions are effectively controlled, and undergo annual compliance, premium, underwriting and claims audits. MGAs (as defined by state law) undergo a second annual claims and underwriting audit. - Partners must have written disaster recovery and business continuity plans, notify the A&H Division within 24 hours of activation, and cooperate on operations during states of emergency. - Partners must cooperate fully in market conduct exams and DOI inquiries, provide timely, accurate, organized information, and coordinate closely with the Group’s exam team. Submission / operational notes - Product and rate filings, form approvals, and advertising approvals are centralized through the Group’s Compliance Department; partners and producers should not independently file or modify forms with DOIs. - Policy and certificate delivery practices (including proof of delivery) are operationally critical to avoid disputes over free-look periods and potential premium refund/commission chargeback exposure. Notable contact points for brokers/producers - General compliance and market conduct questions: Group Compliance Department (email addresses and phone extensions provided in the manual). - Producer appointment and licensing questions: agent.compliance@companiongroup.com. - Market conduct manual access and related compliance resources are highlighted on the "Work with Companion Life" (agents) page on the public site. Overall underwriting / appetite impact - Manual is primarily a market conduct and producer/partner governance document, rather than a risk-class appetite guide. It does not specify preferred or declined industries or case characteristics by line of business. Instead, it establishes binding requirements around licensing, product approval, filings, advertising, privacy, and fair sales practices that govern how any Companion Group program’s underwriting and marketing must be conducted.

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