Michelle Richter

Are You Selling a Verb or a Noun?

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By David Macchia

Advisor Perspectives welcomes guest contributions. The views presented here do not necessarily represent those of Advisor Perspectives.

Meet a woman driven to change investment regulation and understand why it’s important that she succeeds.

Michelle Richter is a principal at Fiduciary Insurance Services, LLC, and executive director of the Institutional Retirement Income Council, Inc. She is also one of the smartest people I’ve ever met. Richter’s intellect incorporates both dimensions of “smart,” which is why she was placed in charge of a Fortune 100 company’s broker-dealer and RIA.

Richter is driven. Her “cause” is reform of regulation that levels the playing field for insurance through the introduction of a 40 Act-equivalent governing insurance advisement. I fully support this because it will result in better outcomes for investors. It will facilitate commercialization of intellectual property that, today, represents unfulfilled potential. To help the advisory profession understand the regulatory inequality that exists, Richter developed her own lexicon, using the “verbs” and “nouns” construct.

I spoke with Michelle on May 22.

I was surprised and enlightened to learn about the construct of the verbs and nouns. I didn’t know it was an issue. What brought you to the realization that we needed this?

There were a few things, but mainly, it’s because my experience is as a person who believes in creating value as an intellectual property developer, and that’s where I’ve spent my career. I’ve worked on a lot of consumer-liability-minimizing concepts, which were good concepts from good people who had good ideas. It became increasingly evident that those ideas couldn’t be commercialized.

Why is it that all these good ideas from good people cannot reach the market? I kept applying things that I had learned previously to arrive at this point, which relates to guidance that I received when I was working at a Fortune 100 insurance company, serving as both an intellectual property (IP) developer and overseer of that entity’s corporate broker-dealer and RIA. At the time, when we were developing that intellectual property, my IP counsel advised me on something that over the past few years has hit me like a ton of bricks.

It related to my IP counsel’s interpretation of the distinction between how an entity defends a trademark versus how it defends a service mark.

That’s what caused me to realize something important. At that time, 15 years ago, we had developed unique IP, and my counsel advised me that because the IP would not be embedded directly into an issuable container, that it should be service marked rather than trademarked. If you Google “trademark definition,” what you’ll see is the ability to profit from one of two things: issuance or sale. Sale means direct remuneration. If I’m selling you X, I’m getting paid for X. Inherent to the definition of trademark-ability is that you can either issue or distribute intellectual property. If you can’t profit from the product, then that product is a “noun.” If you can’t profit from the product, either by issuing it or by receiving compensation directly for it by selling it, then you have to service-mark the IP, because it is a service.

Was it a planning concept, as opposed to a product?

It was a framework for the embedding of insurance values into an asset allocation architecture, where you can value either a life insurance policy cash value, or you can translate the income value of an annuity into asset-based values. Then the value of assets, or the value of income that can be translated to assets or vice versa, is advised upon within the product. The income or accumulation value within the product can have the attributes of either fixed or variable investments, perhaps multiple asset classes within that framework. But the framework was designed to include insurance values within an asset-allocation architecture.

Would that be more like a business process?

It’s a great question. It can be monetized that way. It can also be monetized within a managed account or managed model services.

You could use the insurance values as part of the managed model values. Plenty of people, 10 years later, were doing exactly that.

When I was working at that organization, we did not permit registered representatives to sell managed accounts services because we viewed them as services, not as accounts. I was advised by my general counsel that RIAs sell “verbs,” whereas agents and brokers sell “nouns.”

With respect to managed account services, I was advised that the value for which the consumer is paying does not derive from the form of custodial account. It derives from the advising that occurs on the account.

Registered reps who are not dually authorized lack an investment adviser license that enables them to sell verbs.

Registered reps lack an investment adviser license. But RIAs, including IARs of an RIA, do.

At that time, the essence of the view communicated to me was that things like managed accounts services were verbs. Following from this logic, I believe that the 40 Act governs verb sales, appearing on the left side of the balance sheet, for two reasons. The first is very easy to explain, which is that the 40 Act is short for “investment adviser’s act.”

Investments are assets. Assets occur on the left side of the balance sheet.

But does anyone disagree with you on that?

There are people who viscerally disagree with me because they have not heard that parlance before. There are also people who feel that the point I am making is very complex, so it is understandable to only a very small audience. They would prefer that I discontinue communicating these points out of fear that I might unintentionally confuse people.

There are also people who feel like I am a nut. That’s a valid viewpoint. But I’ve not yet heard an argument that – from anyone – that says, “No. You’re misunderstanding the world.”

I don’t agree that you’re a “nut.” True passion can come across that way, however.

I concluded that the 40 Act governs verb sales by reviewing how organizations supervise it. They require things like routine, ongoing meetings with the client, because advice can only occur at the end of an advising process. Back in my day, meetings that enabled an advisor to advise had to occur at least annually. Things like that are how we can detect what’s occurring under the 40 Act. Those who have the authority to be an investment adviser are verbs. If we were to look at section 202(a)(11) within the Advisers Act, we’d observe that the words that communicate what an investment adviser does end in “ing.” Because that is the case, we can detect a verb in its present form.

The argument that what financial advisors provide is “advice” (a noun) is logically equivalent to saying that what lawyers provide is “law,” as opposed to “ legal interpreting”.

When we add an “r” to the end of a verb to refer to a person, we are describing the identity of the person who routinely performs an action (a verb). We wouldn’t call a person who once ran across the street a “runner.” We call a person a runner when they routinely run, such that part of their identity can be described by adding an “r” to the end of the verb they routinely perform.

This is another way of saying that an advisor is a person who routinely advises. Professional advising means to give advice in exchange for compensation.

 

The other side of the balance sheet, which is involved with liability management, is where the noun sellers live.

That’s one place where noun sellers live. Registered representatives are also noun sellers. The 40 Act made it so that there could be both noun and verb sales in financial services. I am not a historian, but as a layperson, I have heard it said that prior to the advent of the 40 Act, consumers were experiencing behavioral challenges with respect to financial professional conduct when there was only a noun-sale framework. It’s unfair to my community, those who identify with liability mitigation, that we are all seen as inexpert product shillers, like how used car salespeople are viewed.

There isn’t a verb-sale framework for liability management. The only way that we’ve seen people who have that expertise in insurance to be able to monetize their experience and their viewpoint is through noun sales. We don’t have a 40 Act for the right side of the balance sheet. We do not yet have a regulatory construct for advising on benefits or income under management. That this is messed up.

If there were a regulatory framework that allowed advisement on the insurance types of products, in a practical sense, what would they be advising on?

One good example would be the income base within a variable annuity, or for an FIA with living benefits, or for a SPIA. Any of those constructs that has a value to annuitization, or a value to an income stream that could be indicated from within the product, could support a billing base for an adviser if it were the case that we valued liability management as a verb. Something that could and would occur in the event of such a framework is the creation of inspired-by-tontining services. We do not yet broadly have tontining in the United States. We are behind the rest of the developed world in this development of non-guaranteed longevity risk mitigating products or services because we do not have the required regulatory framework. If we had the correct regulatory framework, we would already have a collective defined contribution tontining product (other than what is available from TIAA). Tontining is non-guaranteed risk-pooling for longevity benefits from which you can’t charge a large fee, because the whole premise is about efficiency. For those organizations that have invested in the noun part, which means issuing and/or distributing authority, successful products occur at the intersection of three things: novel intellectual property, issuing authority, and previous investment in distribution – a whole-saleing architecture.

When either a financial professional or an issuing organization can only profit from the noun in the sphere of liability mitigation in the way I just described, then there’s no value to intellectual property, because the issuing authority has to meet the needs of the previous investment in wholesaling. It would make no sense for an issuing organization that has made this substantial investment in distribution to create, and to promulgate, a noun that’s less profitable than is its incumbent portfolio of nouns. The efficient, low-cost asset managers, like Vanguard and Dimensional, came to exist only after there was a 40 Act, and only in the context of the RIA community. RIAs were not being paid from inside the noun. The service of advising is paid based upon the AUM or based upon notional assets that are advised upon, which is to say, upon which advisory services are delivered by a professional.

RIAs are paid for providing a service to their clients from outside the noun structure. All services are verbs.

Because my words are true, there can be no such thing in my field as valuable intellectual property. I experience offense at that.

Imagine that you had a magic wand, and a new regulatory framework appeared tomorrow for agents selling fixed-index annuities.

There would be no protection whatsoever. No financial institution to stand with them as a co-fiduciary under PTE2020-02 for qualified sales.

Let’s say that it existed. Say an agent working with a family consummated a $250,000 transaction to purchase an FIA. What would the latitude be? What would the compensation scheme look like? What would the responsibilities of advisement be in that scenario?

I believe in sentences. The insurance field has parity with the investment field, meaning that we have access to both noun and verb sales. I want to be clear about the fact that no judgment is occurring upon those of us who earn our compensation from selling nouns.

Let’s imagine it comes to be the case that insurance – liability mitigation orientation – is orchestrated around the advising premise as it differs from the product-sales premise. In this world, the placement of the FIA transaction is not the basis for the remuneration that the insurance liability adviser receives. Another way of thinking about that is what the financial planner receives. The value proposition in this case would be the fact that the adviser, the liability adviser, has worked with the client to understand what their needs are. They may recommend that indexed annuity. They may use today’s regulatory framework and get a commission from that. It could be perfectly appropriate. Alternatively, but never concurrently, as is true in the investment space, in my alternative reality, they could and should be able to charge the client on the value creation of the management of that person’s liabilities, instead of the commission that they could receive from the noun within that advising context. Either, but not both concurrently, should be valid compensation constructs available to financial and insurance professionals.

The broader scope of using that is as a strategic tool to manage a certain set of liabilities that the person or individuals have.

Right. That fits well with the premise of codifying financial planning as a discipline.

In part two of this interview, Richter addresses financial planning, the usage of annuities by RIAs, regulatory implications, and more.

Wealth2k® founder David Macchia is an entrepreneur, author, IP inventor and public speaker whose work involves improving the processes used in retirement income planning. David is the developer of the widely used The Income for Life Model®, and the recently introduced Women And Income®. David has authored many articles on the subjects of retirement income planning and financial communications. He is the author of two books, Constrained Investor®, and Lucky Retiree: How to Create and Keep Your Retirement Income with The Income for Life Model®.

View te full article, here: https://www.advisorperspectives.com/articles/2022/05/30/are-you-selling-a-verb-or-a-noun

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The discussion is not meant to provide any legal, tax, or investment advice with respect to the purchase of an insurance product. A comprehensive evaluation of a consumer’s needs and financial situation should always occur in order to help determine if an insurance product may be appropriate for each unique situation.

Ashley SaundersAre You Selling a Verb or a Noun?
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RIAs Sell Verbs. Agents and Brokers Sell Nouns

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I love the insurance industry. It’s not the puppy love I felt when I leapt headfirst into leading my first insurance business. It’s not the coming-of-age identity struggle I faced as my career progressed and I had to decide whether to focus my energy on operations or strategy. Now, I’m talking mature love. When you love something the way I love the insurance industry, you don’t just care about it in your spare time. You want to see it flourish into the best version of itself. Over and over again.

The insurance industry is in an awkward position. It is plagued by product commoditization, prolonged low-interest rates, regulatory mandates ill-matched with insurance distribution, nontraditional entrants effecting tax and capital arbitrage, and generalized disruption. In advising my insurance company clients about how to innovate our way out of these circumstances, I often empathize with Bill Murray’s character in Groundhog Day. Until we begin to acknowledge, and maybe even embrace, the changes, we will be stuck in an endless loop where insurance is perceived as a commodity and where distribution is expensive (which makes products expensive!). Insurance in this world remains isolated from an increasingly integrated, fintech-driven, fee-conscious, financial advisory community.

State insurance regulation governs the conduct of agents and insurance brokers. It needs to be adapted to govern RIAs as well. Insurance advisement is a premise different from insurance sales, just as there is a big difference between the consumer experience of advice versus sales of securities. While some insurance professionals already consult on or about contracts for consumers, and legally charge a fee for doing so, this model is not mainstream for insurance distribution. Insurance regulation currently occurs at the point of sale and does not contemplate ongoing advice. It should be adapted to do so. Such an adaptation would facilitate a transformation of both insurance, which means liability management, and wealth management as disciplines.

There is no direct corollary to the ’40 Act for insurance. There is no national authority that can define the meaning of the term “insurance advis(o)er.” There is no independent national source upon which financial professionals can rely for accurate annuity conduct, oversight and advice.

We are all receiving a high volume of rapidly changing regulatory guidance. It is not always clear how it applies to the nascent world of “insurance advice.” I empathize with the advisors who tell me that there is not one place they feel they can turn to for definitive guidance about what their responsibilities are for various forms of annuity transactions. To try and assist advisors who feel this way, I have compiled the table below. This is not legal advice, but I hope it gives a starting point for a broader discussion in the industry.

Michelle Richter’s Non-Lawyer Best Guess on Applicability of Various Laws to Different Types of Annuity Transactions. Feedback welcome, especially from financial regulatory lawyers!

Read the rest of the article, here: https://www.wealthmanagement.com/insurance/rias-sell-verbs-agents-and-brokers-sell-nouns 

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The discussion is not meant to provide any legal, tax, or investment advice with respect to the purchase of an insurance product. A comprehensive evaluation of a consumer’s needs and financial situation should always occur in order to help determine if an insurance product may be appropriate for each unique situation.

Ashley SaundersRIAs Sell Verbs. Agents and Brokers Sell Nouns
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Retirement Plan Participants Need Help With Retirement Income

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By Rebecca Moore

OUTLIVING THEIR ASSETS is cited by individuals as a top fear about retirement in multiple studies throughout the years.

“Eventually people will retire and will need some help with income,” says David Will, senior financial adviser at CAPTRUST in Allentown, Pennsylvania.

From systematic withdrawals from defined contribution plans to annuities that guarantee a certain income stream in retirement, there are a range of options for plan sponsors to help participants create and manage retirement income. Will suggests that, whether considering an in-plan or out-of-plan income solution or not, plan sponsors should proactively change their plan design to allow systematic withdrawals—periodic or installment payments.

“We’re hearing more from plan sponsors about the need for and interest in retirement income solutions,” says Joel Schiffman, head of intermediary distribution at Schroders in New York City. “I think the challenge remains what direction they should go. It seems everyone’s looking but no one is sure of the right method to take.”

In-plan options are getting more attention these days both because of the Setting Every Community Up for Retirement Enhancement Act and plan sponsor preference for keeping retirees’ assets in the plan, says Michelle Richter, executive director at the Institutional Retirement Income Council, in New York City. She notes that the preference to retain retiree assets has changed from 10 years ago when most did not want to do so. When recently polled, 70% of plan sponsors indicated they do. “This is one reason plan sponsors are seeing a need to create a retirement tier in their plans,” she says.

Another impetus for retaining retiree assets and offering income solutions for them is the Department of Labor’s point of view on rollovers, according to Richter. “Its establishment of PTE 2020-02 signals it wants to prevent rollovers because participants can access less expensive solutions via the plan, and the DOL said in the last year that retention of assets in-plan is a top priority,” she says.

In-plan retirement income solutions that exist range from guaranteed minimum withdrawal benefits, or GMWBs, which is the most flexible and maintains market participation throughout the investment lifecycle, to qualified longevity annuity contracts, or QLACs, which guarantees a nominal amount of retirement income at a certain age in the future. Richter says the range of in-plan solutions are set by those two limits: a GMWB is the most liquid and offers the greatest level of market participation, and a QLAC is the least liquid and offers the lowest level of market participation.

“The challenge is trying to make sense of the alphabet soup of options,” says Richter. “Plan fiduciaries are going to need to become educated on these solutions and what their responsibilities are.”

To help plan sponsors decide which solution to offer participants, Broadridge Fi360 Solutions, Cannex, and Fiduciary Insurance Services have created a consortium that offers two prongs of activities to enable plan sponsors and advisers to become knowledgeable about the choices, says Richter, who helped to create the consortium. “Education on a monthly basis for at least a year and a half is free to plan sponsors and advisers,” she says.

The second prong is to establish objective metrics around each offering to determine which retirement income solution fits plan participant characteristics, Richter explains. “Whether a workforce has longer tenure employees or shorter tenure employees, skews older or younger, as well as their different saving attributes all matter in the process of evaluation for the appropriate retirement income solution,” she says.

“The objective of the consortium is to relay one appropriate process to evaluate which solution is best for a plan, given its attributes,” Richter adds.

As an example, Richter says one product exists that gives accumulation credits. The longer a participant is in that product, the greater the accrual experience towards the rate at which they can annuitize assets. “The product has a unique design where it is more useful for a plan sponsor that has a workforce that tends to be longer tenure,” she explains.

“Knowing the characteristics of each product will help plan sponsors understand how the product will work for its participants,” she says.

Schiffman notes that since the SECURE Act was passed, there’s been a proliferation of retirement income products, but nothing has really caught on at this point. “There is no silver bullet. I think as products come out and plan sponsors dig deeper, they’ll offer multiple options to plan participants,” he says. “Maybe they’ll offer some combination of guaranteed and not guaranteed solutions. The idea of having insurance doesn’t appeal to everyone, and guarantees sound good, but they are costly and complex.”

Read the Full article, here: https://www.plansponsor.com/in-depth/retirement-plan-participants-need-help-retirement-income/

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The discussion is not meant to provide any legal, tax, or investment advice with respect to the purchase of an insurance product. A comprehensive evaluation of a consumer’s needs and financial situation should always occur in order to help determine if an insurance product may be appropriate for each unique situation.

Ashley SaundersRetirement Plan Participants Need Help With Retirement Income
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Episode 134: Picking Nouns or Verbs In Retirement Planning With Michelle Richter

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Language is powerful. It’s exceptionally powerful in the highly regulated world of retirement planning. Michelle Richter, Principal at Fiduciary Insurance Services joins us today to give us a lesson in regulatory grammar and how recent new rules from the Department of Labor may change them.

Also, do you want to get regular updates on news about guests of our show? Subscribe to our newsletter, below! 

We hope you enjoy the show.

Links mentioned today:

Anatomy of Products

Connect with Michelle on LinkedIn: https://www.linkedin.com/in/michelle-richter/

https://www.linkedin.com/posts/michelle-richter_smaller-firms-may-not-be-ready-for-dol-fiduciary-activity-6894979699173666816-Ymo5

https://fiduciaryinsuranceservices.com/fis-glossary/

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The discussion is not meant to provide any legal, tax, or investment advice with respect to the purchase of an insurance product. A comprehensive evaluation of a consumer’s needs and financial situation should always occur in order to help determine if an insurance product may be appropriate for each unique situation.

EPISODE TRANSCRIPTS:

Paul Tyler:

Language is powerful. It’s exceptionally powerful in the highly-regulated world of retirement planning. Michelle Richer, principal at Fiduciary Insurance Services joins us today to give us a lesson in regulatory grammar, and how recent new rules from the Department of Labor may change them. We want to thank our primary sponsor and my employer by day, Nassau Financial Group. We are working harder to be your carrier of choice. We support you with best-in-class service. We seek to keep things simple, and we’ll have your back in years to come. We’re headquartered in Hartford, Connecticut with 19 billion in assets under management, and serve over 400,000 policyholders. We’ve been doing this a long time, 170 years, but remain humble enough to always try to improve. Also, do you want to get regular updates on news about guests of our show? Go to thatannuityshow.com and subscribe to our newsletter today. We hope you enjoy the show.

Intro:

Welcome to That Annuity Show, the podcast that will make you an expert in explaining annuities to your clients. Give us 30 minutes each week, and we’ll shave hours from your client presentations. Now here’s your host, Paul Tyler.

Paul Tyler:

Hi, this is Paul Tyler, and welcome to another episode of That Annuity Show. Ramsey, how are you?

Ramsey Smith:

Very good. Always glad to be here.

Paul Tyler:

Yeah, lot of talk about today. We’ve had an interesting theme running through some of these conversations around language. Jason, we talked about, how do you frame decisions around when to take social security? We had some great discussion with Cyrus on how to describe protective income, and we’re, I think, in that same vein, we’ve got another great guest, returning guest, to talk about a lot of important topics to our business, but also language and what exactly do labels mean and what labels should we adopt. Ramsey, do you want to do the intro?

Ramsey Smith:

So in terms of policing language, I’ll just say that our next guest, this one goes to 11. Right. So, we’re very pleased to be joined today by my good friend, Michelle Richter. Michelle previously, for many years, had worked for a global actuarial firm, and has broken out on her own in the last year or so, and is doing amazingly well with a whole bunch of new clients. We’re very excited to have her on the show, hear about how her business is developing, but also very importantly, hear more about these various topics, these various linguistic issues that we’re dealing with from a regulatory perspective, and frankly, just from an existential perspective in this industry. So, with that, Michelle. Introduce-

Michelle Richter:

It’s going to go deep, Ramsey, if we’re-

Ramsey Smith:

… Tell us about the name of your new business and how you got it started.

Michelle Richter:

… Sure.

Ramsey Smith:

I mean, it’s a great entrepreneurial journey. You’ve recently taken over a new leadership position in the industry as well, and you are publishing-

Michelle Richter:

Yes.

Ramsey Smith:

… more prolifically than I can ever remember. And it’s been great because you put out a lot of good stuff. So rock and roll.

Michelle Richter:

Thank you. Thank you so much, and it’s oh my goodness, it couldn’t be more of a pleasure to be back here. So thank you so much for having me. And the last time that I was here, I earned one of my favorite clients. Did you [crosstalk 00:03:54] tell you this?

Ramsey Smith:

No. No.

Paul Tyler:

We need these stories. So where-

Ramsey Smith:

Please, tell us.

Michelle Richter:

Yes.

Ramsey Smith:

Go ahead.

Michelle Richter:

Yes. So, I’m now working with RISA profile, who is a previous guest of yours and the relationship started not with the time that I flew to Texas, basically just to meet Wade Pfau, in the middle of the night, that made no impression whatsoever. It was my appearance on That Annuity Show that Alex Maria saw that caused him to reach out and say, “Yeah, we maybe could benefit from working together.”

Paul Tyler:

… Excellent.

Michelle Richter:

But he was right.

Ramsey Smith:

That is fantastic. Look, I think one of the most satisfying things about this show is that… And we always say the guests make the show, Paul and I just are lucky enough to be here. The guests make the-

Paul Tyler:

By the way, I’m just hanging on to Ramsey, that’s all.

Ramsey Smith:

… Not hardly. The guests make the show, but part of it is the guests get to be there… You get to be your best self. And we keep on hearing stories like this, where there’s been a great sort of point of inflection career-wise or otherwise after appearing on the show. So we love these stories and as you develop more from your appearances, share them with us, because we’d love to hear them.

Michelle Richter:

I, on one hand, I hope I get more, but on the other hand, because I’m at capacity not taking new clients until 2024, I kind of hope that doesn’t happen.

Ramsey Smith:

Can I tell you that is such a boss move, right? It’s a boss move. I love this. So Michelle sends a note out. I don’t know whether this is in LinkedIn or elsewhere, and said, “I just want everybody to know I’m booked til 2024. So if you had any designs on working with me, you missed out. See you in 2025.”

Michelle Richter:

It-

Ramsey Smith:

That was such a great move. That was so baller.

Michelle Richter:

… Thank you. Thank you very much. And that’s actually the third time this week I’ve been called that.

Paul Tyler:

All right.

Michelle Richter:

I’m not even kidding.

Ramsey Smith:

Fantastic.

Michelle Richter:

I’m living my best life.

Ramsey Smith:

There you go.

Michelle Richter:

I can’t deny it.

Ramsey Smith:

All right. So for-

Michelle Richter:

Yes, to business.

Ramsey Smith:

… Tell the audience what you’ve been up to.

Michelle Richter:

Yes. So my business is incredibly creatively named Fiduciary Insurance Services, just like any good insurance person would do just name exactly what you’re doing. But to be a little less, not funny, but a little more serious, the way that I saw what I wanted to do and what I wanted to be was fiduciary, which is somebody who takes very seriously their responsibility to their clients and is prepared to represent that they’re the superlative. That they’re the best. So a fiduciary is somebody who’s prepared to represent. I’m giving you my best advice. I’m doing the absolute best and I’m the best in my… Or I’m within the best class of my community. And so insurance because insurance is what I’m obsessed with and services is I do verbs. I sell verbs and I don’t sell nouns.

Ramsey Smith:

So this really at the heart of frankly sort of the way this point of inflection in your career and your life. So we should dig it a little bit deeper. And I told Michelle before the show, I’ve borrowed her nouns versus verbs paradigm for a presentation I’m giving later this week. So thank you for that. And again, full credit to Michelle Richter for that wisdom.

Michelle Richter:

No. I’m so glad it resonated.

Ramsey Smith:

But let’s talk about that. Tell us about the nouns versus verbs paradigm and why you think it’s a way to describe the difference between the traditional fiduciary and what we do on the insurance side.

Michelle Richter:

Yeah. And it’s, the amount of information that I’m going to be able to tie back to this premise is going to be pretty incredible. I think when we see at the end of the show. But at this moment, I would expect the audience to be pretty skeptical that it’s going anywhere good. In all seriousness though, insurance is… So I’ve had the great pleasure of having had the opportunity to run a corporate RIA, a multi-billion dollar IA for a fortune 100 insurance company. And I also had the good fortune of being a product developer, or I should say an intellectual property developer, which ultimately was service marked at that time by virtue of the distinction in my mind between nouns and verbs.

Michelle Richter:

And so in running an RIA and in also running an insurance business, I think a person winds up… And a person who sits in the seat of regulatory principle for those entities winds up with a lot of background information on the regulatory frameworks under which either verbs or nouns are compensated. And one incredibly important tenant that I feel doesn’t get communicated to financial professionals well enough is that one does not receive compensation for both at the same time. So one-

Ramsey Smith:

Can you hold on just one second, because I want to make sure the audience understands who sells what? So let’s just start with the basics. And if you said that, I’m sorry I missed it, but-

Michelle Richter:

… No, I didn’t. I didn’t.

Ramsey Smith:

… Okay. Let’s talk about who sells nouns and then who sells verbs.

Michelle Richter:

Agents and brokers.

Ramsey Smith:

Got it. Okay.

Michelle Richter:

RIAs.

Ramsey Smith:

RIAs, sell verbs.

Michelle Richter:

RIAs sell verbs. Correct. And agents and brokers sell nouns. And to the extent that any verbs get provided in the sale of those nouns, they are solely incidental to the noun sale. That’s what the loss is.

Paul Tyler:

Okay. So, sorry. Sorry. Let me go really slow. So I am an insurance agent-

Michelle Richter:

Yeah, let’s go super slow.

Paul Tyler:

… I sell Ramsey and annuity. I’m selling him a noun.

Michelle Richter:

Yes. Yes.

Paul Tyler:

I help Ramsey plan for retirement that possibly could benefit from an annuity. Am I breaking law, because I’m not a licensed planner?

Michelle Richter:

Only if you’re charging for the service.

Paul Tyler:

Okay. So if I’m charging for the verb, it’s a problem. If I’m charging for the noun, I’m okay. Okay.

Michelle Richter:

Yeah. That’s right.

Paul Tyler:

I like this.

Michelle Richter:

Right. Because you sell nouns. Sell means receive remuneration and exchange for.

Paul Tyler:

Is that a bad thing?

Michelle Richter:

No, it’s a wonderful thing. I buy nouns all the time. And for me, it’s just really important to know what’s happening right now. Am I buying a noun or am I buying a verb? So when I go to look at a house and I did. The last time I bought a condo, I used a real estate agent and she received a commission for helping me and there was no chance I was going to do all that work on my own, and thank God she was there. Right. But she wouldn’t call herself my real estate advisor. She was my real estate agent. She helped me buy and sell the property, which is a noun.

Ramsey Smith:

Okay. So I think that before long, you’re going to have to turn all this into a schoolhouse rock song.

Paul Tyler:

Yes.

 

Ramsey Smith:

It’s just-

Michelle Richter:

It’s true. But there’s so much obvious… Excuse me, so much confusion. Intentional confusion created around the differentiation between those regulatory frameworks. And that’s why I’m constantly on LinkedIn correcting people for saying things like that.

Paul Tyler:

Sure. Well, and I’m looking at the clock it’s February. February 2021. This was a big month for nouns and verbs in the insurance space. And I don’t know if we get here now or, we Ramsey, we wait a little bit. Because I’m confused. I’m noun and verb confused as are many people in this business.

Michelle Richter:

Yeah. Well, yeah. I mean, so I think, Paul we’re talking about DOL or the Department of Labor’s rollover guidance and how it impacts our community as distinct from how it impacts other pieces of the financial professional ecosystem. And it’s going to be a really challenging time in our space, I think, as we all figure out how it is that we’re supposed to operate under these new expectations. In the past, it was either the DOL took the perspective that a one time transaction, which is what insurance is, because it historically has been.

Michelle Richter:

Now in sales, it’s usually not. Doesn’t meet what DOL calls that five-part test for under ERISA. But since they reinterpreted it and since they’re going to be applying prohibited transaction exemption, 2020-02 and revising an old prohibited transaction exemption, that would have been relied upon by the insurance industry, if they were not revising it, it creates this unbelievably confusing landscape for our industry to be operating in. And we kind of don’t know exactly how so some of these things will shake out as they’re coming before July 1st, as they’re looking into how to enforce this. But it’s going to be impactful to agent business models and in part, because for the fixed noun sellers in our space, there is no regulatory overseer that can serve as financial institution for them.

Ramsey Smith:

… So. All right. Let’s just walk it back here. Right?

Michelle Richter:

Stop. Yeah. Okay.

Ramsey Smith:

So let’s go the life of an agent. Let’s take an agent. Let’s talk about what that means. So I’m an agent, I go out and I have clients, I’m selling my nouns. I come across a client, that’s got money and I want to do a rollover. Let’s go specifically what the day to day experiences for a noun seller, aka an agent.

Paul Tyler:

Right. And it’s one noun versus another noun. If the noun is a qualified noun.

Michelle Richter:

Yeah. So if you’re selling qualified nouns now, if you want to qualify for prohibited transaction exemption, 2020-02, you need to have a financial institution that oversees your conduct and that can sign with you, that you are acting in a fiduciary capacity. That’s really new for our world. And it does not fit with demutualization. So meaning it does not fit with not career agents, because the insurance companies will not serve as co-fiduciary. So, because that is how it is panning out, and the fact that the industry had intended instead of allowing agents to use 2020-02 with the insurer as co-fiduciary, they instead indicated that they would use PT8424, which is an old exemption. But labor’s now modifying that. The material difference between those laws or those abilities to roll that money over is 2020-02 requires you to be a fiduciary. Whereas, 8424 just requires disclosure of compensation that it not be unreasonable. And you’re not claiming to be a fiduciary.

Paul Tyler:

Okay. One piece of trivia PTE84, why was it named 84 Ramsey? Do you know?

Ramsey:

I don’t know. The numbers are so different.

Paul Tyler:

It was-

Ramsey:

I don’t know why they’d be so different.

Paul Tyler:

… so creative.

Ramsey:

Do tell.

Paul Tyler:

It was written in 1984. That’s it.

Ramsey:

Right. Was the other one written in 1922?

Paul Tyler:

No.

Ramsey Smith:

So you lost me, man.

 

Paul Tyler:

No, PTE20, 2020. It was written in 2020.

Ramsey Smith:

Oh 2020. Oh, fair enough. Got it. Yeah. We’re in a new century.

Paul Tyler:

Right. Just to help it-

Ramsey Smith:

Go figure.

Paul Tyler:

… It kind of helps you think. Well, it actually, a little bit of trivia actually helps because all the insurance companies are relying on this definition 81984 to protect us right now.

Michelle Richter:

Right. And think about it, it hasn’t been revised since then, because nobody needed to rely upon it, because nobody was tripping up the five-part test in how it was being interpreted before. But now that it’s being interpreted differently, now the industry is needing to rely on one of those PTs. And in the case of an independent agent there isn’t an overseeing. They would oftentimes work with an IMO or FMO to help with marketing, but those organizations aren’t responsible for regulatory oversight. So that places them in an awkward position because they’re going to need to attest for themselves that they have satisfied 81984.

Ramsey Smith:

Well, so let’s talk about that. What should they do? Should they go out and find a financial institution? So the insurance companies won’t help them. The IMOs at this point, aren’t set up to do it. Although, I know that in the previous iteration with the DOL there were some IMOs that were thinking about adding that capacity. But that’s still developing it best, right?

Michelle Richter:

Yes. Developing at best. I hope. I hope it develops.

Ramsey Smith:

Okay. But, what can they do now? Do they have to sit on the sidelines or what can they do?

Michelle Richter:

I think we’re going to find out. I think that’s what’s under negotiation at the moment.

Ramsey Smith:

[crosstalk 00:18:37].

 

Michelle Richter:

Right. So-

 

Paul Tyler:

Yeah. I’ll give you late-breaking, real-time picture. We had a number of our distributors for meeting and talked exactly about this topic. And question from one of our distributors, well, wait a second, if our agent doesn’t… If the agent says they did this and got the client and they have the records, but they don’t, who’s liable here? Michelle, is there a difference between a fiduciary with capital F or a small F in this world?

Michelle Richter:

… So if they’re relying on 8424, then they’re not a fiduciary. I do not know how they’re going to modify the language in 8424, yet. But my hope is that it’s tight. But I think there will be material negotiation that’ll occur around this. I think what is likely at the moment is that there will be an expectation of best interests being met. I don’t think that 8424 is going to go as far as fiduciary or that somebody going to have to rep for that. 2020-02 does do that, but the industry isn’t looking to use it. And the industry is looking to modify 8424, and I think it will come shy of that representation. But it’s still being negotiated.

Paul Tyler:

Well, as an aside, there actually, a lawsuit was filed in Texas to challenge this. And Ramsey, I actually got an inbound, unsolicited inbound of the people wanting to come on our show and talk about their lawsuit. So I don’t know, Michelle, what do you think? Would that-

Michelle Richter:

Tell me more. What lawsuit? What happened?

Paul Tyler:

… There’s a lawsuit challenging this, the DOL rule filed in Texas.

Michelle Richter:

Oh. Oh. Oh, I know what you’re talking about.

Paul Tyler:

Filed in Texas by an industry group. I would suspect there’ll be more. We’ll see more in an effort to better define what does this mean. Verb versus noun. Crazy. Crazy world.

Michelle Richter:

Yeah. Well, yes, I think there’s going to be another round of clarifications before anything goes into effect for… As relates to the July 1st deadline. Not as relates obviously to the February 1st deadline. I expect we’re going to see more clarification.

Ramsey Smith:

So first of all, Paul, sure. Why not? We should have them on if they have something to say.

Paul Tyler:

Right. Right.

Ramsey Smith:

But now, so now Michelle, the next piece of this, you developed some very sort of strong opinions and you, right? But no-

Michelle Richter:

Yes.

Ramsey Smith:

…. and you share them and you address some pretty important organizations pretty directly, like FINRA, the SEC. So now, most people do that with some trepidation. You are-

Michelle Richter:

That’s true.

Ramsey Smith:

… You are fearless. And I’m curious have they-

Michelle Richter:

That’s because I’m cracked.

Ramsey Smith:

… Good on you. I mean, so have you ever gotten any response from them yet? Do you expect at some point you might hear-

Michelle Richter:

Not yet.

Paul Tyler:

Interesting.

Michelle Richter:

I hope so, because I’m not tagging them to be silly or to annoy them. I’m tagging them on points that I think are really important for them to consider. And in particular as it relates to the identities of people who distribute insurance, I think there’s insufficient guidance given as it relates to those intersections between how one interacts in an insurance community relative to a wealth managing community.

Ramsey Smith:

… Okay. You gave a good segue there, because we talked about this. We talked about in a world where we all spend a lot of time thinking about identity, sometimes it cuts both ways. Sometimes it’s good. Sometimes, it’s great to some issues obviously in the broader society. But in here, in this space, you came to a really interesting realization about the business you wanted to build and this distinction between services and things. And-

Michelle Richter:

That’s right.

Ramsey Smith:

… And the place, the very unique place you wanted to carve out. So, so tell us about that discovery process and then how you’ve implemented it into a business.

Michelle Richter:

Okay. This is going deep guys. And it’s going to be real fun.

Ramsey Smith:

That’s how we roll.

Michelle Richter:

Okay. All right. So, I fashion myself an intellectual property developer. Okay. That’s how I’ve spent a material portion of my career doing that. Okay. So with intellectual property, you obviously need to have protections for it so that other people don’t copy your work and that you have enough time to build it into a business. So one thing that’s become very apparent to me over the… slowly, but then suddenly… over the last 20 years of developing intellectual property is this realization that the way in which one does business, when one sells verbs is really different from the way that one does business, when one sells nouns. And since the insurance world where I have grown up and spent my whole career and where I am obsessed is where it’s at as an industry is that we do not have a verb based lens to look at insurance through.

Michelle Richter:

Insurance, there’s no 40 Act corollary in the insurance space. Some adaptations around the premise that there are advised assets inside of annuities, for example, on which fees can be charged, creates a little bit of an intersection between those communities. But it’s very ill defined how one could experience insurance through a verb based lens. So the realization that I had, as I said, over a 20 year period of developing IPs, is that the really unique IP developers that have made a low cost investing environment possible we’re able to do so because of the verb based compensation system. So if an advisor, and by advisor I mean person acting in an advice capacity, and by which that means verb provider, so a person providing verbs can weave together, weaves a verb, the products, products are nouns.

Michelle Richter:

So think Vanguard or think Dimensional for people who manage assets on the podcast. These are entities that are really well regarded for being able to provide lower cost, intelligent product noun solutions. They’re popular in the RIA community because the RIA earns money for delivering verbs. There can never come to be a Vanguard or Dimensional in my community because my community only has available to it a noun based compensation system. And because that’s true… Okay. So because my community can only profit from noun sales, the only way in which we develop intellectual property is as nouns. But because products sell in insurance only if there has previously been an investment in both manufacturing and in distribution, it can never be the case that intellectual property on its own can be valuable in insurance.

Michelle Richter:

And because it is so expensive to invest in that issuing authority and distribution infrastructure, there will never be an incentive for a noun based infrastructure to use low cost intellectual property. So because all of these things are true and because my community doesn’t have a verb based understanding, there can be no value to intellectual property in my community, which means there’s no value to me in my community. That’s where I reached the end of the rainbow, if you will.

Ramsey Smith:

This is like the Pythagorean theorem of like… When you first showed it to me I thought this, it reads like a geometric proof.

Michelle Richter:

Yeah. Well, it also is a geometric proof. Yeah.

Ramsey Smith:

Okay. There it is.

Michelle Richter:

I did literally QED three dots and a triangle, kind of pull it out. But yeah, back into that logically, like when you have that awareness of your own experience and believe me, it motivates you to the point where you want to just blow up the world or make another world. Another world in which there exists a verb based architecture for my industry.

Ramsey Smith:

Okay.

Paul Tyler:

You know-

Ramsey Smith:

Go ahead, Paul.

Paul Tyler:

… Okay. Well, a lot of layers here, Ramsey. I’m going to tick the first one off, which there’s just kind of a reflection, Michelle. At a prior company, we sold a lot of our nouns through a big association. You know this association because, one of your prior companies sold the very same powerful one. And they actually, their compensation was literally intellectual property charge. Which made no sense because there wasn’t any intellectual… It was truly, they were the verb. They were creating this collection and this community and continually keeping a cohesive community, but their compensation structure was based on something that wasn’t quite descriptive. I’m not saying inaccurate, but it was not descriptive what they were doing.

 

Michelle Richter:

That’s obviously a different regulatory thing. So it would, to be able to be compensated that way and not to be overseen as a noun seller, I imagine was beneficial for them.

Paul Tyler:

Now, are you arguing that there’s… What if I’m a distributor and I’ve come to a carrier and I’ve brought them a wonderful product idea, and I want to get compensated based on an idea brought to them, is that not intellectual property?

Michelle Richter:

Yeah. So they can charge asset based fees on that concept. That concept will be valuable to a manufacturer if and only if it illustrates better than does the incumbent product portfolio that the carrier already has.

Paul Tyler:

It’s Ramsey.

Ramsey Smith:

Paul, you’re letting that sink in. I can tell.

Paul Tyler:

Look labels important. I think back to, again, back to some other companies. I mean, we had whole committees, Ramsey, deciding what noun was appropriate, would we allow our agents to be called. This noun was a suspect noun. This noun is a legitimate noun, or adjective, I guess.

Ramsey Smith:

OR versus ER?

Paul Tyler:

Yes. Certified retirement.

Michelle Richter:

Who has not sat through a two hour long compliance versus distribution dispute on the spelling of that word? Raise your hand if you haven’t.

Paul Tyler:

But this is an important topic. And you’re right, we’re right, framing language over the next six months will be critical for a lot of industries. And Ramsey, great question, who’s liable. You say the IMOs are not really… A lot of the distributors are not set up for… Have giant compliance arm. But they also don’t have, Michelle, one of the other advantages of a noun based company is it has deep pockets so that you have one agent who goes awry or a client who’s just ridiculous in demands or feels upset later. You got money to pull from. From the future. Whereas your distributor, your bank account probably isn’t that big.

Michelle Richter:

100%. So that’s why somebody has to be out there defending the individual distributors because they don’t have… They’re not able to rely a financial institution that oversees them and that helps them to comply with the regulations as they keep getting amended. And frankly, the whole regulatory structure that exists in the insurance space evolved from the fact that insurance companies were mutual at the time when the regulations were established. And because that was true, distribution coexisted with manufacturing. And because that was true, it was important for the insurance companies to train their agents really effectively to understand their products, to explain them well. And all of this is all occurring because of demutualization. Because distribution no longer is controlled by the same entity that issues products. And that creates this disjointed regulatory experience where the individual financial professional, instead of the, as to your point, the giant issuing company, the financial professional is the person who needs people like you guys to be out there communicating with them about what responsibilities really are.

Ramsey Smith:

This is like a philosophy class, like alienation. I feel like I’m back on campus, Paul.

Paul Tyler:

Yes.

Ramsey Smith:

So-

Paul Tyler:

Yeah. I’ll share you my notes after the show, if you trade me yours.

Michelle Richter:

There’s no scale in this class. Everybody’s getting-

Ramsey Smith:

So let’s-

Michelle Richter:

Mark the [crosstalk 00:33:51].

Ramsey Smith:

… There’s two things. One is like, okay demutualization process happened at some point in the history and what are all the sort of knock on effects that were unexpected that happened? That’s a whole discussion. And then there’s-

 

Michelle Richter:

It is.

Ramsey Smith:

… Then there’s a discussion that you having come to this conclusion said, “I’m going to build my own business and I’m going to build one that is relevant in this sort of bizarre construct.” So tell-

Michelle Richter:

Right. Exactly right.

Ramsey Smith:

… So tell-

Michelle Richter:

In my bizarro world where-

Ramsey Smith:

… I didn’t say you were bizarre. I said that-

Michelle Richter:

… No. No, you didn’t. I did.

Ramsey Smith:

… I said it was the situation, and you sort of identified with sort of the unique, and so-

Michelle Richter:

So from my perspective, what I want to do is create meaning behind the term insurance advisor. I view myself as a person who advises institutions and academics and life insurance companies about insurance. But because there’s no meaning to this term yet, I’m kind of going out there trying to claim it. I certainly would prefer somebody else took care of it. But to the extent that it-

Ramsey Smith:

… It’s yours. Keep it.

Michelle Richter:

… But to the extent that that’s not occurring, then that’s important to me to make sure that it occurs, because I do not want to leave the next generation that follows me in the circumstance that my generation was in where there cannot be such a thing as valuable intellectual property in their field. That’s lame.

Ramsey Smith:

All right.

Michelle Richter:

So insurance advisor-

Ramsey Smith:

That’s the sound bite right there.

Paul Tyler:

Yeah.

Ramsey Smith:

We’ve gone through, just this tremendous sort of vocabulary journey and we boiled it down to this is lame.

Michelle Richter:

… Right. Well, it is. But it is, because I mean, I’ve seen so many good product ideas over the years and people not be able to launch them and not know why. Well, here’s the why. Read NCHA, it’s a noun based world and-

Ramsey Smith:

Told you, Paul.

Michelle Richter:

… So there should be a verb based world for my people, because I have a tribe that’s valuable over here and we provide services that are really important to our communities, so you know.

Paul Tyler:

Maybe we could get a gerund that would sort of fit in between. What do you think, Ramsey? Gerund.

Ramsey Smith:

Yeah. I get it. Yeah.

Paul Tyler:

Insurance gerund.

Michelle Richter:

Yeah, exactly. I mean-

Ramsey Smith:

What would it be?

 

 

Michelle Richter:

… But a gerund is a verb. But it’s really, I know that I sound like maniac, but I’m telling you guys the truth. The end result of there being no over-based infrastructure, no over-based regulatory environment is that there are no dimensionals in the insurance base and there can’t ever-

Ramsey Smith:

So here’s another controversial question. So, we talked about how in insurance, there’re state regulators and obviously in securities you’ve got FINRA, SEC, so who is the boss of you right now? In this new-

Michelle Richter:

Nobody.

Ramsey Smith:

… Okay. So, but say that one more time.

Michelle Richter:

Me. Me, I’m the boss of me. My boss is a maniac. She’s a complete lunatic. No, that’s just the thing it’s-

Ramsey Smith:

From a regulatory perspective, I mean.

Michelle Richter:

… I have no regulatory overseer and that’s troublesome. Because we’ve all seen the effects of my conduct. But think about that on LinkedIn, having the complete freedom to just say that which is true. It’s been pretty amazing. But at the same time, I’m a rules follower I’m a rules explainer. I’m maybe a little bit at the edges of rules. Let’s not say breaker, but bender. I jaywalk routinely. And in any case-

Ramsey Smith:

You live in New York, yeah.

Michelle Richter:

Yeah. Yeah, yeah, yeah. So any case. But the point is, as I was beginning on my journey to figure out what do I want to do with my life and career, and I was trying to figure out under what regulatory framework does one monetize intellectual property, or can one, and there totally is not one. I have a 65, I formed an RIA. I have not yet used that RIA. I haven’t done any business out of it. I provide strategic consulting on an hourly basis and nobody oversees that. And that’s troublesome. There should be a regulator.

Ramsey Smith:

Is there some regulator that thinks they oversee that? The part of it, isn’t just-

Michelle Richter:

No.

Ramsey Smith:

… Sometimes, if it’s enough, if they… Somebody, if an entity or somebody in the government feels that they oversee it, then they can obviously… They have the power to make that happen. Do you think that that’s a… Anybody like that exist thus far?

Michelle Richter:

I would like for that to happen, but no.

Ramsey Smith:

That’s interesting. So You want that, that would be-

Michelle Richter:

Yeah, I do.

Ramsey Smith:

You think it’s a problem that there isn’t somebody that’s thinking about this from a regular bucket.

Michelle Richter:

Yes.

Ramsey Smith:

That’s a very… Because in one sense you’re breaking glass and on the other sense, you’re like, “Okay, but there needs to be somebody. There needs to be a referee here.”

Michelle Richter:

Yeah. Can’t be codified. It can’t be repeated until there’re eyes on it and process to make it verb. You know what I mean?

Paul Tyler:

Okay.

Ramsey Smith:

All right. Well then-

Michelle Richter:

Then it’s not repeatable without that.

Paul Tyler:

Working-

Ramsey Smith:

… Go ahead.

Paul Tyler:

… No. Go.

Michelle Richter:

Then it’s not repeatable without that.

Paul Tyler:

Go ahead. No go, Ramsey.

Ramsey Smith:

We’re at the top of the hour. So I warned, Michelle before we started this, because Michelle who’s always sort of hyper prepared, sent us a whole I’ll call it a treatise because this has been a philosophical conversation. So we had plenty of things to talk about and we said that there’s way more than we can ever cover today. I think, we’ve done… actually, we’ve done a great job covering a lot of things. This has been a great conversation. And, Michelle, this is your third tour here, and you’ll certainly-

Michelle Richter:

That’s right.

Ramsey Smith:

… We’ll certainly have you back again. Have back again this year.

Michelle Richter:

Well, thank you guys.

Paul Tyler:

Absolutely.

Ramsey Smith:

This has been great.

Paul Tyler:

Yeah. Michelle, hey, thanks so much.

Michelle Richter:

Thank you.

Paul Tyler:

I know your solidly booked. So if you’re clients listening to show, don’t call her. Okay. Don’t. But if somebody wanted to find out… Okay, first of all, you’re on LinkedIn. Great. I recommend connecting or following you. Where else? What? Your website. How else should we find you?

Michelle Richter:

Yes. I have a website, fiduciaryinsuranceservices.com. And I also serve as executive director for the Institutional Retirement Income Council, which is a nonprofit think tank in the defined contribution space. And that website is an absolute treasure trove of information for those people who do serve an in-plant community. That’s IRIcouncil.org.

Paul Tyler:

Excellent. Michelle, thanks so much. Ramsey, it was a pleasure and-

Michelle Richter:

A lot of fun.

Paul Tyler:

… as always, listen, we appreciate all our listeners, and of course our guests. But keep ideas coming. People we should pull on and-

Ramsey:

But give us victory stories.

Paul Tyler:

… Yes.

Ramsey Smith:

You came on the show and it, somehow it led to a victory in your life or career. Share that with us. It’s super important.

Paul Tyler:

Yeah. Please. Please. Okay, terrific. Hey, thanks so much and tune in again next week-

Michelle Richter:

Thank you guys.

Paul Tyler:

… for another episode of That Annuity Show.

Outro:

Thanks for listening. If you’ve enjoyed the show, please rate and recommend us on iTunes, Stitcher, Overcast, or wherever you get your podcast. You can also get more information at thatannuityshow.com.

Ashley SaundersEpisode 134: Picking Nouns or Verbs In Retirement Planning With Michelle Richter
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Episode 102: Readying RIAs to Effectively Offer Annuities (And Many Other Topics) With Michelle Richter

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Michelle Richter, Principal at Fiduciary Insurance Services, joins us again to cover a wide variety of important industry topics. One of many that jumped out in today’s conversation was the need for structural change in how the annuity industry services RIAs in the future. Some of these involve technology, other products, and probably not surprisingly, how we better provide training about how to use insurance in financial plans. However, who will pay for training and how will it be delivered? Join us today for these topics and more.
Also, keep up with news from our guests and sign up for our email list at thatannuityshow.com.

Useful URLs for Retirement Plan Advisers from IRIC include:

https://iricouncil.org/wp-content/uploads/2021/06/IRIC-DC-Income-Product-Program-Compilation-v6.3.21.pdf 
https://iricouncil.org/wp-content/uploads/2018/03/Evaluation-Scorecard-for-Retirement-Income-Products.pdf
https://iricouncil.org/wp-content/uploads/2019/09/plan-sponsor-guide-to-retirement-income-decision-beleifs-ii.pdf
https://iricouncil.org/evaluation-tools/#1520343622078-7c3a5514-60bf
https://iricouncil.org/wp-content/uploads/2018/03/Debunking_Portability_Myths.pdf

Thank you to our show sponsor, The Index Standard!

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The Index Standard is your answer. They are an independent provider ratings and forecasts on all indices and ETFs used in the US insurance space. Their process is systematic and unbiased, identifying robust and well-designed indices.

We all know finance is complex and The Index Standard has a clear ratings system and uses approachable language to demystify this complexity. Visit theindexstandard.com for more information.

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The discussion is not meant to provide any legal, tax, or investment advice with respect to the purchase of an insurance product. A comprehensive evaluation of a consumer’s needs and financial situation should always occur in order to help determine if an insurance product may be appropriate for each unique situation.

Ashley SaundersEpisode 102: Readying RIAs to Effectively Offer Annuities (And Many Other Topics) With Michelle Richter
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Episode 48: How Will The Annuity Landscape Change This Year With Michelle Richter

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Michelle Richter, Managing Director of Retirement Enhancement Solutions at Milliman, joins us to share her insight on changes in product, distribution, and the consumer market.

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Show Sponsors

The discussion is not meant to provide any legal, tax, or investment advice with respect to the purchase of an insurance product. A comprehensive evaluation of a consumer’s needs and financial situation should always occur in order to help determine if an insurance product may be appropriate for each unique situation.

Nicholas BreniaEpisode 48: How Will The Annuity Landscape Change This Year With Michelle Richter
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