BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                  SB 1170
                                                                  Page  1

          Date of Hearing:   June 20, 2012

                           ASSEMBLY COMMITTEE ON INSURANCE
                                 Jose Solorio, Chair
                      SB 1170 (Leno) - As Amended:  May 1, 2012

           SENATE VOTE :   38-0
           
          SUBJECT  :   Insurance: Sale to Seniors and Senior Veterans

           SUMMARY  :   Expands consumer protections governing the sale of 
          insurance to Seniors, and adds specific protections for Senior 
          Veterans.  Specifically,  this bill  :   

          1)Makes it an unfair sales practice to fail to disclose to a 
            veteran, in connection with advertising for events, seminars, 
            workshops and related activities concerning veterans benefits, 
            that the promoters are not authorized to represent veterans in 
            the application for or appeal of the denial of veteran's 
            benefits.

          2)Requires this disclosure to be made in at least the same size 
            type as the word "veteran" or similar words is used in the 
            advertising, and requires the disclosure to be repeated both 
            orally and in writing at the beginning of the event.

          3)Makes it an unfair sales practice for any advertising for a 
            veterans event, seminar, workshop and related activities that 
            is not sponsored by the California Department of Veterans 
            Affairs or the United States Department of Veterans Affairs 
            (VA), or other Congressionally designated veterans 
            organization, to fail to contain a specific statement that the 
            event is not sponsored by these governmental agencies.

          4)Prohibits an insurance agent who is not an attorney from 
            delivering to any person 65 years of age or older a living 
            trust or other legal document if the purpose is the sell the 
            senior an insurance product.

          5)Prohibits an insurance agent who is an attorney from 
            delivering a living trust or other legal document to a person 
            65 years of age or older, if the purpose is to sell the senior 
            an insurance product, unless a detailed disclosure that is 
            currently required of attorneys is provided by the insurance 
            agent.








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          6)Expands the definition of "advertisement" in the senior 
            insurance consumer protection law.

          7)Adds veterans organizations to the list of entities whose 
            logos may not be copied or used, or similar images created, in 
            a manner that implies endorsement by or a connection with that 
            organization.

          8)Prohibits use of terminology in written materials that is 
            similar to or could deceive the prospective senior purchaser 
            that the policy is offered by a veteran's organization.

          9)Prohibits advertising for products intended to be sold to 
            seniors to imply that the sale is endorsed or associated with 
            the Social Security Administration or Department of Veterans 
            Affairs.

          10)Requires a specified notice that current law requires to be 
            provided at least 24 hours before a visit to the home of a 
            senior to sell insurance be provided no earlier than 14 days 
            prior to the visit, and requires this notice to be in at least 
            16-point font in a stand-alone document.

          11)Requires this notice to contain the agent's full name, 
            license number, telephone number and address, and contain 
            specific statements that "I am a licensed insurance agent" and 
            "My purpose for coming to your home is to sell, discuss, or 
            deliver" an insurance product.

           EXISTING LAW :

          1)Specifies 24 separate acts or practices that constitute unfair 
            practices in connection with the sale or lease of goods or 
            services.

          2)Establishes a comprehensive regulatory system specific to the 
            sale of insurance products to seniors, but does not include 
            specific provisions addressing veterans, and issues unique to 
            veterans.

          3)Prohibits an insurance agent from paying commissions to an 
            attorney for the referral of a policyholder.

          4)Requires, at least 24 hours prior to a visit to a senior's 








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            home to sell insurance, that an agent provide a notice, in at 
            least 14-point font, that specifies a series of rights the 
            senior has, including the right to have other persons present, 
            to terminate the meeting at any time, and specifying who will 
            be attending and the Department of Insurance contact 
            information.

           FISCAL EFFECT  :   Because the bill was referred directly from the 
          Senate Appropriations Committee to the Senate Floor pursuant to 
          Senate Rule 28.8, it appears that any costs would be minor and 
          absorbable by the Department of Insurance.

           COMMENTS  :   

           1)Purpose  .  According to the author, despite certain consumer 
            protections for veterans in connection with various Veterans' 
            benefits, insurance agents have been targeting higher wealth 
            veterans with misleading and abusive marketing strategies that 
            have less to do with legitimate financial management and more 
            to do with selling these veterans insurance products.  In 
            addition, the bill is aimed at preventing inappropriate 
            charges for "assisting" veterans in the application for, or 
            appeal of the denial of, veterans benefits.

           2)Background  .  The Aid and Attendance Program is a federal VA 
            program designed for low-wealth veterans who cannot afford 
            medical supplies or in-home care services.  According to a 
            recent General Accounting Office (GAO) study, the program is 
            being abused by insurance agents and others who arrange with 
            wealthier veterans to have their assets placed in trusts or 
            deferred annuities, thereby qualifying them for benefits.  The 
            GAO report also found that inappropriate fees were being 
            charged to these veterans despite the federal program's ban on 
            fees to assist a veteran to apply for benefits.

          For the past decade, there has been an ongoing Legislative focus 
            on the financial abuse of seniors, but these efforts have not 
            focused specifically on some of the issues that directly 
            affect veterans.  It appears that efforts to protect seniors 
            generally have focused some of the less scrupulous market 
            participants who find unique ways to take advantage of certain 
            seniors, in this case those who might be eligible for federal 
            benefits.

          The GAO report also noted that the lack of a federal financial 








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            "look back" requirement is enabling the Aid and Attendance 
            Program's resources to be unwisely spent on veterans who may 
            not be the Program's target population.  While this bill 
            cannot address that loophole in federal law, it can address 
            the tactics that enable to loophole to be exploited.

           3)Support  .  Supporters argue that certain financial predators 
            manipulate seniors and veterans into believing that they 
            possess special knowledge or special connections to legitimate 
            organizations, and then charge exorbitant fees in connection 
            with transactions.  In particular, supporters note the focus 
            on veterans, and the financial manipulations necessary to 
            "qualify" otherwise not qualified veterans for certain VA 
            benefits intended for the less wealthy veteran population.  
            Supporters also argue that these financial predators have 
            found ways to get around some of the existing protections for 
            seniors, such as "complying" with notice requirements for 
            in-home meetings so far in advance, or so buried in voluminous 
            documentation, that these laws need the updates provided by 
            the bill.

           4)Past and Related legislation  .  SB 1184 (Corbett) would 
            prohibit an insurance agent from having a financial interest 
            in an entity to which he or she refers a client in connection 
            with veterans benefits.  The bill is pending in the Assembly.

          AB 689 (Blumenfield), Statutes 2011, Chapter 289, adopted 
            "suitability" standards with respect to the sale of annuities 
            to seniors.

          SB 620 (Scott), Statutes 2004, Chapter 547, enacted a 
            comprehensive senior insurance protection law.

          AB 2150 (Berg), Statutes 2008, Chapter 327, adopted restrictions 
            on the designations insurance agents may use to describe 
            themselves, where the designation suggests special expertise 
            or trust.

           REGISTERED SUPPORT / OPPOSITION  :

           Support 
          
          California Advocates for Nursing Home Reform (sponsor)
          AARP
          AFSMCE








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          American Legion, Department of California
          AMVETS, Department of California
          California Alliance for Retired Americans
          California Association of County Veterans Service Officers
          California Commission on Aging
          California Senior Legislature
          Consumer Federation of California
          Department of Insurance 
          Vietnam Veterans of America, California State Council
           
           Opposition 
           
          None received.

           Analysis Prepared by  :    Mark Rakich / INS. / (916) 319-2086