Broker compensation template, 408(B)(2). How brokers need to disclose their compensation. - Shared screen with speaker view
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Is this recorded
If we wish to review it later, will it be sent out?
Misty indicated that ys
What about 1/1/22 renewals?
What about renewals that do not require any paperwork to renew?
Robert W Locke Sr
I am not getting any audio. It just abruptly stopped.
How do you account for the general agent's override in the broker disclosure?
If an agent shares comp by giving a bonus to an admin does this need to be disclosed or just who the commission is paid to?
What if we don't know the commission prior to getting the employer application completed?
Does this include Voluntary Plans?
Would the $1,000 be an aggregate of all plans that are provided to the client or is it on a per plan basis?
Is this is for health Insurance products only?
If we just list the commission percentage is that adequate. Or do we have to list the actual dollar as we don't what future enrollment will be or do we know who will elect what line? Is this ALL lines of coverage.
Small group is 'age rated', so what information or how to report?
is life and di subject to commission disclosure?
What about Colonial, AFLAC, and Vol. Life
Is this for small and large group in Maryland or just large group please? Thank you.
If carriers pay bonuses, but as a small agency we know we will not qualify, do we need to disclose any information about dollars we will not receive?
Will carriers begin to include the disclosure within their renewal?
Some employers add employees without our knowledge. What then?
If we offer free resources to clients, do we have to disclose this (ie. HR & on-line portal)
What period of time is the $1000 based on?
which law put this rule into effect?
Is this for individual policies too?
Do you have a sample disclosure form.
You said that disability and life is excluded but then said it's not product related and that ALL compensation is included...
yes they are going to give you a template.
it is for group
individual plans and short term medical disclosures are provided by the carrier
I'm for the government and I'm here to help!
Template in the next few slides
May we include the carrier commission schedule with this disclosure form, when sent to the client?
Young Kim...no. If you have the plan sold & signed before 12/27, no disclosure
You'll be providing the PEPM rate or the % of comp, if that comp is more than $1K.
id like to know how they are going to monitor this LOL
Would we include gross comp? i.e. we receive 100 total income and have a partner broker we share 50/50 with would the disclosure be 100 or 50?
Is it $1,000 combined for all lines/plans, or per line of coverage? So we make $2k for medical, we disclose. If we make $150 for COBRA, do we disclose that to or could we leave that off?
So hospitals, PBMs and insurance companies can continue to operate with impunity and the brokers get stuck with this BS, got it.
But as long as we do our 2022 renewals before 12/27 we don't have to do it for them but going forward would apply. Is that correct? Do you expect further guidance as this sounds like a lot of extra work and it may get changed before we need to begin.
so does it have to be disclosed for all clients/prospects by 12/27 or just as they renew?
If we have subcontractors or split commission - does each broker need to fill out a form for their individual direct and indirect compensation?
Is the $1,000 all inclusive of Medical, Dental, & Vision or is it $1,000 per line. What do we do in situations where it is a sliding scale (not uncommon for vision).
large gruop renewals include comp %. would this meet teh requirment
If I receive a 5% commission, do I need to estimate a dollar amount for the year?
how are over-rides reported?
Regarding indirect compensation, is it reasonable to disclose compensation based on the coverages likely to be placed versus all 30 coverages shown on a spreadsheet?
Is a producer service fee direct or indirect?
eh em...there are no overrides 😇
What if commission from carrier comes through BenefitMall?
Is this for all options shown or just the option selected by the carrier -
this is a good question
‘I Rebel Because My Mom Was Too Strict On Me,’ Says Teen
What if the charge for the "Enrollment system" is a pass through. If the broker is charged $1PEPM and then they charge the client the $1 PEPM?
"Reasonable", so rent control basically.
I thought I heard Misty say do not include Life & Disability but David say to include Life & Disability. Please clarify as I misunderstood.
Is it $1000 per group or per line over coverage or service? If you have 3 lines of coverage and each is under $1000 do you have to disclose?
so does it have to be disclosed for all clients/prospects by 1227 or just as they renew
For clarity... we completed renewals for 11/1 and now for 12/1 are these disclosures held off until next renewal?
A carrier may give a bonus for retention to the agency. The agent may have no idea. What does the agent do?
What happens if the Employer does not send it back to you?
Wow. Disclosure of any gift, golf, meal? When did we become elected officials?
Let's go Brandon!
LETS GO BRANDON
So fill out these forms and then send them to your clients if/when they request them or are audited by DOL? got it
Cant we just do it as a firm?
IE: MABS receives 3%
Can you point to this section you are discussing
Next up, restaurants disclose how much they paid for their wine list bottles.
Guys - the bill was passed in Dec of 2020 BEFORE we had to start dealing with LGB .. ugh!
After I deal with all of the compliance that I don't get paid for, I will start doing my job helping my clients.
President Trump signed the CAA. This disclosure requirement was not from Biden.
To Tom Street - I agree!
I our agency receives 100% of the commission but then pays a portion out to a sub producer, are we required to disclose the entire (100%) of the commission or only the portion we retain.
Rhonda Peters Titus
Thank you John Deem you beat me to it!
Do licensed service staff who are paid a salary have to disclose compensation since it is made up of commissions?
IS PEO comp included?
If a 1/1/22 Health renewal is automatic with no signature, do we have to disclose?
1. do we disclose the entire commission as a firm or does each assigned agent on the case have to disclose separately -
It feels like that in an audit if we can show we sent the disclosure that should be good enough, right?
2. do we disclose to prospects/clients by 12/27 or upon their renewal?
is this requirement on all size groups?
Can you post the link to download the template here?
where can we download the template
How would you list a graded commission schedule?
Were to we go to download the template on the website again?
This is the link
Just to confirm, if less than $1K in compensation is received from the group, no requirement for disclosure?
And the link will be provided on the email.
Misty: Regarding co brokers disclosures, is this regardless of the agency listed on the application?
If I am a co-broker and disclose the full compensation, does the other broker need to disclose?
In addition to the above question - if the co-broker is 1099 not paid by the carrier how is that disclosed?
if split 50/50 and commish is $1800, each broker gets $900. So NO letter is required, correct?
If our agency collects 100% commissions but pays out sub agents there portion of the commissions, do the sub agents have to report or just our agency??
IS IT DISCLOSED ON RENEWAL OR JUST AFTER 12/27
On the form is it annually or monthly that is being reported?
What happens when a client reduces employee count during the year. My expected commission will be less than initially stated.
How / When do we report a group that has one line of coverage renewaing in Feb and the rest in July?
Do we have to do this "every year" or just once after 12/27/21? Assuming no new lines or carriers were sold.
Your referrences to $1,000 do not specify annual or monthly comp, so I assume you mean annual.
does this include P&C?
In lieu of a dollar amount you displayed earlier that disclosure can be as an example "3%" does that suffice?
does it include life and DI.
I listened to a similar webinar conducted by NAHU. This is 1000% better.
Will you share this recording and presentation after the meeting?
Sounds like Voluntary Plans are included if you can expect to receive over $1K ….
Renewal means contract renewal date correct?
What if it pays 5% and I receive 3%? Do I determine based on my 3%?
This is an ERISA regulation but applies to services outside of ERISA? How does that work.
Sorry if I missed this ...… Is it $1,000 for all lines/plans combined? For example, If we make $800 on medical, $400 on dental, $200 on vision, do we disclose?
will this include group voluntary plans or just medical, Dental, Vision
In case you missed it
you've done a great job! Thank you!
Please, if our agency makes $2000, but I only receive $1000 compensation/commission, how is this handled.
Thanks for the webinar ... very informative!!
I agree, amazing presentation!
Please answer Jessica's question. It is very important.
Do you have employer information from DOT that we can provide to the employer on why we are providing this disclosure.
Do we have to send this form every year?
Can you please make the answers to all the questions here available to us after the webinar is over?
Thanks - Great Presentation!
Thank you both! Well presented and explained.
You too are awesome!!!! Thank you for doing this for us.
Well done -- you've added value to my day
cannot manipulate form
Many thanks, this was very helpful :)
Maybe y'all should do another one with just questions and answers. :-) Thank you! This is a big one.
Thank you. Appreciate the info.
Thanks so much for the information