Compliance Questionnaire - Life insurance sector

Part A - General Information

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Date questionnaire was completed:
If operating as a sole practitioner: Your name and address:
Organization's legal name and operating name (if it differs) and head office address (if you are answering as a partner, administrator or employee):
Please indicate the type of premises for the above address: Commercial / Retail, Residential / Dwelling House, or (If other, specify)
Name and title of the individual completing questionnaire:
Contact information:
Business telephone:
Business fax:
E-mail:

Are you or your organization a Managing General Agent (MGA) or an Associate General Agent (AGA)?
Yes (Please start at question A1)
No (Please start at question A6)
Both, AGA and MGA (Please start at question A1)
Other (Please start at question A6)

A1 - Do you or your organization engage in the sale of life insurance products?

A2 - If you or your organization is a MGA, how many AGAs do you have contracts with?

A3 - If you or your organization is a MGA, do you also act as an AGA for another MGA?

A4 - If you or your organization is an AGA, how many MGAs do you have contracts with?

A5 - How many insurance brokers / agents do you have business dealings with?

A6 - How many life insurance companies do you or your organization have contracts with? Federal companies __________ Provincial companies __________

A7 - Do your contracts with the life insurance companies outline each party's responsibilities?

A8 - Who regulates you or your organization (check all that apply)? Provincial Financial Services Commission
Provincial Insurance Council
Mutual Fund Dealers Association (MFDA)
Provincial Securities Commission
Investment Dealers Association (IDA)
Other (please specify)___________________________

A9 - How many employees are there in your entire organization (if applicable)?

A10 - Do you or your organization have branch offices or locations situated in Canada?

A11 - If you answered yes to question A10, please list in which provinces these branch offices are located.

A12 - Do you or your organization have branch offices located outside of Canada?

A13 - If you answered yes to question A12, please list in which countries these branch offices are located.

A14 - Do you or your organization have clients residing outside of Canada?

A15 - During the previous fiscal year, what was the approximate percentage of your or your organization's business that was related to the following product lines? (Note: percentages should be based on premiums/revenues)
Life Insurance _____ %
Securities (including mutual funds) _____ %
Annuities (including segregated funds)_____ %
Property & Casualty Insurance _____ %
Accident & Sickness Insurance ____ %
Group Life and Health Insurance _____ %
Other _____ %

A16 - During the previous fiscal year, what was the approximate percentage of your or your organization's activities that were related to the following life insurance products: (Note: percentages should be based on premiums/revenues)
Whole Life/Participating _____ %
Term Life _____ %
Segregated Funds _____ %
Annuities _____ %
Universal Life _____ %
Group Life and Health_____ %
Critical Illness _____ %

A17 - What is the approximate total premium value of life insurance products that you or your organization has written during the previous fiscal year?

A18 - What is the approximate total revenue that you or your organization has earned from life insurance activities during the previous fiscal year?

A19 - What forms of payment do you or your organization accept for the purchase of life insurance products (check all that apply)? Cash Cheque Bank draft / money order Pre-authorized payment Other _______________

A20 - What is your or your organization's primary bank / credit union / caisse populaire / trust company?

A21 - What is your or your organization's secondary bank / credit union / caisse populaire / trust company?

A22 - Have you or your organization been subject to an anti-money laundering compliance review by your regulator since June 12, 2002?

A23 - If you answered yes to question A22, what is the name of the regulator and the date of the last review?

A24 - Is your organization a wholly owned subsidiary of any other entity subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and Regulations? If yes, what is the name and address of the parent organization? For types of entities subject to the Act, refer to FINTRAC's website Guideline 1:
http://www.fintrac-canafe.gc.ca/publications/guide/Guide1/1-eng.asp

A25 - Do you or your organization own any other entities that are subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and Regulations? If yes, what are the names and addresses of these entities? (Examples would include businesses engaged in the sale of real estate and securities)

A26 - Are you or your organization engaged in any other activities that make it subject to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and Regulations? If yes, please list.

If you are a life insurance carrier or manufacturer, please go to question A27.
If not, please go to section B.

A27 - How many associate general agents or managing general agents do you have contracts with?

A28 - How many brokers do you have contracts with?

Part B - Compliance Regime

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B1 - Have you or your organization fully implemented a compliance regime? Refer to FINTRAC's website Guideline 4:
www.fintrac-canafe.gc.ca/publications/guide/Guide4/4-eng.asp

B2 - If no, at what stage of implementation is your or your organization's compliance regime. Should you require more space, please attach a separate sheet with the relevant information. Please specifiy the information relates to question B2.

Part C - Compliance Officer

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C1 - Have you or your organization appointed a compliance officer who is responsible for the implementation of your compliance regime?

C2 - If yes, please provide the name and title of the compliance officer.

C3 - Does your compliance officer report directly to senior management of the organization? (Senior management could be the owner or chief operating officer of the business, any senior executive or any member of senior management or the board of directors)

C4 - How do you or your organization keep up with any changes in reporting, record keeping or client identification obligations?(Check all that apply)
Media (newspaper, television, etc.)
FINTRAC's Website
Other websites
Seminars, training or conferences
Insurance companies with whom you do business
Associations
Other

C5 - Have you consulted the FINTRAC Guidelines?

Part D - Compliance Policies and Procedures

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D1 - Do you or your organization have policies and procedures to ensure your reporting, record keeping and client identification requirements are being met?

D2 - If you answered yes to question D1, are your or your organization’s policies and procedures in writing?

D3 - Who has the task of filing your suspicious transaction reports with FINTRAC?
You / Your organization
Your Agents

If you are a Managing General Agent (MGA) or an Associate General Agent (AGA), please go to question D4. If not, please go to question D6.

D4 - Do any of the insurance companies you or your organization have business dealings with deny or delay the issuance of the insurance policy, if you or your organization does not provide all client identification required by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and Regulations?

D5 - Do any of the insurance companies you or your organization have business dealings with deny or delay the paying of commissions, if you or your organization does not provide all client identification required by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and Regulations?

D6 - Do you or your organization cross-reference the names of clients with any anti-terrorism lists of names published by the Canadian government? For more information about these, please refer to Consolidated List of Names published by the Office of the Superintendent of Financial Institutions at http://www.osfi-bsif.gc.ca by referring to the "Suppression of Terrorism" link.

Part E - Review of Compliance Policies and Procedures

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E1 - Have you implemented a process for reviewing your or your organization's compliance policies and procedures to determine their effectiveness?

E2 - Has such a review already been conducted for you or your organization?

E3 - If you answered yes to question E1 how often will you or your organization conduct a review?
More than once a year
Once a year
Less than once a year

E4 - If you answered yes to question E2, who conducted the review: (Check all that apply)
Compliance officer
Internal Audit
External Audit
Consultant
Other

E5 - If you answered yes to question E2, when was the review completed?

E6 - Are the results of the review documented?

Part F - Ongoing Compliance Training

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F1 - Do you or your organization provide training regarding your reporting, record keeping and client identification obligations?

F2 - Describe how your training is delivered. Include information about the mode and frequency of delivery as well as a general description of who is required to take the training. If there is not enough room below, attach a separate sheet to provide all the relevant information. Make sure to indicate that this information belongs to answer F5.
Mode of training
In a classroom with trainer/seminar
Computer-based
Self-directed
Other
Frequency of training
Annually
More often than annually (quarterly, etc.)
When new staff is hired
In special circumstances
Other
Who receives the training:
Brokers & agents (if different method of delivery, please describe)
Only those in contact with clients
Managers
Back office staff
Corporate security
All staff
Other
Type of material
Handouts
Test administered with pass or fail mark
Presentation or group discussion
Other

If you are a Managing General Agent (MGA) or an Associate General Agent (AGA), please go to question F3. If not, please submit the questionnaire.

F3 - Do you or persons within your organization receive training regarding reporting, record keeping and client identification obligations by any of the insurance companies you or your organization deals with?

F4 - Describe how that training is received. Include information about the mode and frequency of delivery as well as a general description of who is required to take the training. If there is not enough room below, attach a separate sheet to provide all the relevant information. Make sure to indicate that this information belongs to answer F5.
Mode of training
In a classroom with trainer/seminar
Computer-based
Self-directed
Other
Frequency of training
Annually
More often than annually (quarterly, etc.)
When new staff is hired
In special circumstances
Other
Who receives the training
Brokers & agents (if different method of delivery, please describe)
Only those in contact with clients
Managers
Back office staff
Corporate security
All staff
Other
Type of material
Handouts
Test administered with pass or fail mark
Presentation or group discussion
Other