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BlogInsurance

Disclosure for Small Face Amount Life Insurance Policies: A Comprehensive Overview

Maya
By Maya
Last updated: September 9, 2025
10 Min Read
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The Disclosure for Small Face Amount Life Insurance Policies Model Act is designed to ensure that consumers are provided with clear, meaningful information when purchasing small face amount life insurance policies. Small face amount policies are often simpler, more affordable options, but they come with unique features that can affect policyholders’ decisions, such as the total premiums paid over time and the accumulation of costs.

Contents
  • Purpose of the Small Face Amount Life Insurance Policies Model Act
  • Definition of Small Face Amount Policy
  • Exemptions from the Model Act
  • Disclosure Requirements for Small Face Amount Life Insurance Policies
    • A. Premium and Face Amount Disclosure
    • B. Available Premium Payment Plans and Product Alternatives
    • C. Cumulative Premiums and Riders
    • D. Free-Look Period and Policy Cancellation
  • Insurer Duties Under the Model Act
  • Effective Date of the Model Act
  • Chronological Summary of Actions
  • The Importance of Transparent Disclosures

This post provides a detailed summary of the model act, highlighting the key provisions regarding the disclosure of policy terms, the responsibilities of insurers, and the exemptions related to specific types of insurance policies.

Purpose of the Small Face Amount Life Insurance Policies Model Act

The primary goal of this model act is to ensure that policyholders understand the terms of their small face amount life insurance policies before making a purchase. These types of policies, typically with a face amount of $15,000 or less, often involve premiums that accumulate over time, sometimes exceeding the initial face amount of the policy.

By establishing clear disclosure requirements, the act seeks to eliminate confusion and ensure consumers are aware of how much they will pay in premiums, as well as the potential for premiums to exceed the face amount. This model act aims to foster transparency and protect policyholders from unexpected costs or misunderstanding of the policy’s terms.

Definition of Small Face Amount Policy

A small face amount policy refers to a life insurance policy with an initial face amount of $15,000 or less. The face amount is the initial sum guaranteed to be paid out upon the death of the insured, and small face amount policies are typically designed to provide affordable life insurance coverage to a broad range of consumers.

This threshold of $15,000 is the standard set forth by the model act, although states have the flexibility to adopt a different monetary face amount based on their local requirements. Small face amount policies are often used as entry-level options for individuals seeking simple, inexpensive life insurance coverage.

Exemptions from the Model Act

While the Small Face Amount Life Insurance Policies Model Act applies to most individual and group life insurance policies, there are several exemptions to ensure that certain policies are not unnecessarily burdened by the disclosure requirements. These exemptions include:

  • Variable Life Insurance: Policies where the death benefit and cash value are tied to market performance or other investment variables.
  • Individual and Group Annuity Contracts: These are financial products that provide a fixed stream of income, not life insurance.
  • Credit Life Insurance: Life insurance policies issued to cover debts or loans in case of the insured’s death.
  • Group Life Insurance: Policies issued to members of a group (such as employees or members of a professional organization) where premiums are paid by the group or through payroll deduction.
  • Policies with Illustrations: If the life insurance policy has an illustration that meets the requirements set forth in the Life Insurance Illustrations Model Regulation.

These exemptions help to focus the disclosure requirements on the most common types of small face amount life insurance policies, allowing for a more streamlined regulatory framework.

Disclosure Requirements for Small Face Amount Life Insurance Policies

The core of the Small Face Amount Life Insurance Policies Model Act revolves around the disclosure requirements that insurers must adhere to when issuing small face amount policies. The act outlines several crucial disclosures that must be made to the policyholder prior to policy delivery:

A. Premium and Face Amount Disclosure

Insurers must clearly and prominently disclose to the policyholder that, over the term of the policy, the cumulative premiums paid may exceed the face amount of the policy. This disclosure must be made before the policy is delivered to the policyholder. It’s essential that the policyholder understands this aspect of their policy, as it directly impacts their long-term financial commitment.

B. Available Premium Payment Plans and Product Alternatives

If the cumulative premiums are expected to exceed the face amount, the insurer must also disclose any available premium payment plans or product alternatives. If no alternatives exist, the insurer must clearly inform the policyholder that there are no such alternatives.

This ensures that the policyholder is fully informed of their options and can make an informed decision about whether to proceed with the policy or explore other life insurance options.

C. Cumulative Premiums and Riders

The cumulative premiums paid for a small face amount policy should include premiums paid for any riders attached to the policy. Riders are additional benefits added to a base policy, such as accidental death or critical illness coverage. However, the face amount of the policy does not include the benefits provided by the riders.

This clarification ensures that policyholders understand the full financial commitment they are making when purchasing a small face amount life insurance policy, especially if they are adding riders for additional coverage.

D. Free-Look Period and Policy Cancellation

One of the most important consumer protections included in this model act is the free-look period. The free-look period allows the policyholder to cancel the policy within 10 days of policy delivery, providing a full premium refund with no charges or penalties. This provision gives consumers the opportunity to reconsider their decision and ensure that the policy they’ve chosen aligns with their needs and expectations.

The free-look period must be clearly and prominently disclosed in the policy, so policyholders are aware of their right to cancel the policy if they change their mind.

Insurer Duties Under the Model Act

Under this model act, insurers and their producers (agents or brokers) have a duty to assist policyholders by providing information about the disclosure statement if the policyholder has any questions. This requirement ensures that insurers take an active role in helping consumers understand the terms of their small face amount policies and the potential costs associated with them.

Insurers are responsible for ensuring that the disclosure requirements are met before policy delivery and that the consumer receives all necessary information to make an informed decision about their insurance coverage.

Effective Date of the Model Act

The Disclosure for Small Face Amount Life Insurance Policies Model Act becomes effective on the date specified in the legislation. States that adopt this model act must ensure that it applies to insurance policies and certificates issued on or after the effective date. This ensures that the new requirements are implemented in a timely manner and apply to all new policies sold after the adoption of the law.

Chronological Summary of Actions

The NAIC first adopted the Disclosure for Small Face Amount Life Insurance Policies Model Act in 2001. In 2005, amendments were adopted to refine the disclosure provisions, and the act was reprinted and adopted by the NAIC Plenary. These updates were designed to strengthen consumer protection and enhance transparency in small face amount life insurance policies.

The Importance of Transparent Disclosures

The Disclosure for Small Face Amount Life Insurance Policies Model Act is a critical piece of legislation aimed at protecting consumers by ensuring that they receive clear, meaningful information about their small face amount life insurance policies. By requiring insurers to disclose the potential for cumulative premiums to exceed the face amount of the policy, as well as any available alternatives, the act helps consumers make more informed decisions about their coverage.

The inclusion of a free-look period further protects policyholders by providing them with an opportunity to cancel the policy and receive a full premium refund if they change their mind. These protections ensure that policyholders are not locked into policies that may not meet their financial or coverage needs.

For insurers, adhering to these disclosure requirements not only helps them stay compliant with the law but also fosters trust and transparency with their clients. By promoting clear and honest communication, the Small Face Amount Life Insurance Policies Model Act benefits both consumers and the life insurance industry as a whole.

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