A step-by-step compliance checklist for advisors licensed in BC to use when delivering an ivari Universal Life policy to a client. Designed to align with the Insurance Council of BC Code of Conduct and the Financial Institutions Act.
📋How to use this checklist: Work through each section with your client present. Check each box only after confirming the client understands and acknowledges. Retain a signed copy for your file.
Section 1 of 6
Advisor & Disclosure Requirements
Complete these items before reviewing the policy with the client. Required under the Marketing of Financial Products Regulation and the ICBC Code of Conduct.
1
☐ Advisor Identity Disclosed
Confirm your full name, licence number, and the name of your agency/MGA have been provided to the client in writing.
2
☐ Insurer Disclosed
Client has been told this policy is issued by ivari. The name of the insurance company providing the product has been disclosed as required.
3
☐ Conflicts of Interest Disclosed
Any business or financial interest you or your agency has with ivari has been disclosed to the client, including compensation arrangements.
4
☐ Needs Analysis on File
A documented needs analysis confirms this policy was suitable for the client's needs, objectives, and financial circumstances at time of sale.
5
☐ Replacement Declaration (if applicable)
If this policy replaces an existing policy, the Life Insurance Replacement Declaration has been completed, signed, and provided to the client prior to delivery.
Section 2 of 6
Policy Basics — Confirm Client Understanding
Review the main parts of the policy with your client to make sure they understand what they bought.
1
☐ Explain Policy Type
The client knows this is a Universal Life insurance policy, which combines permanent life insurance with an investment account in one contract.
2
☐ Review Death Benefit Option
The client understands their death benefit option—either Level or Increasing—and how it affects the policy's cost.
3
☐ Review Cost of Insurance
The client knows if their policy cost is fixed or increases yearly, and that monthly costs are automatically taken from their investment account.
4
☐ Explain Premium Payments
The client understands the minimum amount they need to pay and that they can choose to pay more to grow their investment, as long as it stays within tax rules.
5
☐ Confirm Ownership & Beneficiary
The client knows who is listed as the beneficiary and understands they can change this at any time, unless they have named an irrevocable beneficiary.
6
☐ Explain Free Look Period
The client knows they have a set time to review their policy and can return it for a full refund if they change their mind.
This section is critical. ICBC Code of Conduct requires that clients fully understand non-guaranteed elements. Do not proceed until all items below are confirmed.
⚠️Regulatory Requirement: Clients must understand which elements of this policy are guaranteed and which are not. Failure to explain non-guaranteed elements clearly may constitute a breach of your licence conditions.
1
☐ Investment Options Reviewed
Client has reviewed all available investment options: Treasury Bill, Fixed-Rate (1/5/10 yr), and Index/Fund-Linked options. Client understands the difference between each.
2
☐ Non-Guaranteed Returns Disclosed
Client understands that Index and Fund-Linked options can go up or down, including negative returns, which will reduce their Total Fund Value. Past performance does not guarantee future results.
3
☐ Treasury Bill Floor Explained
Client understands the T-Bill option uses a formula-based rate that never falls below 0% — a protection against negative returns in that specific option.
4
☐ Fixed-Rate Guarantees Explained
Client understands fixed-rate options lock in a rate for 1, 5, or 10 years with a minimum guaranteed return, but are subject to market value adjustments if withdrawn early.
5
☐ Policy Bonus is NOT Guaranteed
Client understands that the annual ivari Policy Bonus is discretionary — it may be added based on fund size and performance, but is not guaranteed and should not be relied upon.
6
☐ Illustration Basis Disclosed
If a policy illustration was shown, client understands which values are guaranteed and which are non-guaranteed projections only. Actual results may differ materially from illustrated values.
Section 4 of 6
Impact of Investment Performance on Coverage
Client must understand how poor investment performance or fund deductions can affect their insurance coverage and policy longevity.
1
☐ Fund Depletion Risk Explained
Client understands that monthly deductions come from the fund. If the fund falls too low to cover charges, the policy enters a 31-day grace period — and lapses if not replenished.
2
☐ Death Benefit Reduction Risk Explained
Client understands that loans, withdrawals, Living Benefits, and negative investment returns can reduce the death benefit paid to their beneficiary.
3
☐ Tax-Exempt Status Conditions Explained
Client understands the policy is designed to remain tax-exempt under Canadian rules. If the fund grows too large relative to coverage, ivari may increase the Face Amount or move excess funds to a taxable Side Account.
4
☐ Side Account Explained
Client understands the Side Account earns a guaranteed formula-based rate (never below 0%), is accessible at any time, and is subject to income tax on interest earned — unlike the main policy fund.
5
☐ Long-Term Nature of Policy Emphasized
Client understands this policy is best treated as a long-term plan. Surrender charges are highest in the early years, and short-term surrender may result in significantly reduced or no cash value.
Section 5 of 6
Accessing Cash & Surrendering
Review all options for accessing money inside the policy, and the risks and costs associated with each.
Policy Loans
☐ Client understands they can borrow against the policy up to a maximum amount
☐ Client understands loans accrue interest and reduce both fund value and death benefit if unpaid
☐ Client understands loans can be repaid at any time to restore full value
Withdrawals
☐ Client understands partial withdrawals have a minimum of typically $500
☐ Client understands one free partial surrender per year is available after policy year 2
☐ Client understands withdrawals may trigger surrender charges and market value adjustments
Living Benefit
☐ Client understands the Living Benefit is available from policy year 6 upon serious disability or critical condition
☐ Client understands taking the Living Benefit reduces both the fund and the death benefit
Full Surrender
☐ Client understands they can cancel the policy at any time and receive the Net Cash Surrender Value
☐ Client understands surrender charges are higher in the early years
☐ Client understands market value adjustments may apply to fixed-rate investments upon surrender
Section 6 of 6
Client Acknowledgement & Advisor Attestation
To be completed and signed by both the client and advisor. Retain a copy in the client file as required by ICBC record-keeping obligations.
Client Acknowledgements
☐ I have received and reviewed my ivari Universal Life policy
☐ I understand my policy includes an investment component and that returns are not guaranteed
☐ I understand that investment losses can reduce my fund value and death benefit
☐ I understand that illustrated values are projections only and not guaranteed
☐ I understand the policy is long-term in nature and early surrender may result in reduced value
☐ I understand my right to return the policy during the free look period
☐ I have had the opportunity to ask questions and all my questions were answered to my satisfaction
Advisor Attestations
☐ I delivered the policy in person (or via agreed method) and reviewed it with the client
☐ I disclosed my name, licence number, agency, and the insurer's name
☐ I disclosed all actual or potential conflicts of interest
☐ I explained all non-guaranteed elements of the policy clearly
☐ I confirmed this policy continues to be suitable for the client's needs
☐ I have documented this delivery meeting in the client file
☐ A copy of this completed checklist is retained in the client file
📁Record-Keeping Reminder: Retain this signed checklist and all related documentation in the client file. ICBC may request documentation to confirm the transaction meets client needs and was conducted appropriately. Inability to provide records may be considered a breach of licence conditions.