Medicare & Senior InsuranceQuestion 311 of 315

A California producer recommends that a 68-year-old client surrender his existing deferred annuity and purchase a new annuity with a different carrier. Under California Insurance Code §10509.4 and the CDI replacement regulations, the producer must:

a.Submit a signed 'Notice Regarding Replacement of Life Insurance and Annuities' to both the existing insurer and the replacing insurer, list every existing contract being replaced, and ensure the consumer receives required comparison disclosures; failure to comply may result in fines, license suspension, and unwinding of the transaction
b.Make the recommendation orally and document it only after the client signs the new application
c.Use any disclosure form chosen by the producer, with no requirement to notify the existing insurer
d.Skip replacement disclosure if the transaction is between two products at the SAME insurer

Explanation

Under California Insurance Code §10509.4 and the CDI's replacement regulations (10 CCR §2698.30 et seq.), a 'replacement' transaction — defined broadly to include any new policy whose purchase involves discontinuing, surrendering, lapsing, forfeiting, or otherwise reducing benefits on an existing life or annuity contract — triggers strict notice and comparison requirements. The producer must (1) present and obtain a signed 'Notice Regarding Replacement,' (2) list each contract being replaced, (3) submit the notice to BOTH the existing and the replacing insurer, and (4) provide written comparison information. Option B is wrong; oral, post-application recommendations violate the rules. Option C invents producer discretion. Option D is wrong; INTERNAL replacements at the same insurer are still subject to replacement rules (with limited exceptions). Senior replacement scrutiny is especially high.

Law Reference: California Insurance Code §10509.4 (replacement of life and annuity contracts)

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