"Working as a Self-Employed Actuary"
The Self-Employed Actuary Julie Curry, FSA, MAAA Curry Actuarial Consulting LLC (770) 630-4354 Outline of Presentation Risks and rewards of self-employment Career path toward self-employment Profile of a successful small business owner Steps to starting a business Running a small business: administrative issues Case Studies Question & Answer 2 My Background Life Insurance Company - 8 years – Financial reporting expertise Ernst & Young Consultant – 6 years – Consulting (M&A, financial reporting, etc) – Audit support (Statutory, GAAP) – State Ins Dept examination support Independent Consultant – 13 years – Life insurance company financial reporting – Financial reporting systems implementation – Audit support (audit firms, dept of ins) 3 Types of Actuarial Jobs Insurance/Reinsurance Co (Life, Health, PC) Pension/Benefits Actuary Educator Consulting – Actuarial consulting firm – Pension/benefits consulting firm Regulatory (Dept Ins, Fed Govt, other) Other (banks, etc) 4 How to Decide Path Interest and aptitude based on college course work Perceived advancement opportunities Strength in interpersonal skills Ability of various jobs to offer actuarial students study time Geographic limitations 5 First Job: My Decision Process Summer internship at life insurance company Interviews through college placement office were all insurance companies Looked for company with actuarial study program and rotation program Goal of staying close to home (Columbus OH) Ended up at Capital Holding (Life Ins Co) in Louisville KY Company assigned me to financial reporting 25+ years later, I’m still in financial reporting! 6 Factors in Job Changes External Factors – Position eliminated – Spouse transferred Internal Factors – Perception of better opportunity or lower stress elsewhere – Desire to increase compensation – Interest in changing career tracks Ins co to consulting or vice versa Desire to move to teaching position or regulatory job 7 Becoming a Self-Employed Actuary It’s not the first step in a career path! If this is your ultimate goal, each step in career path should keep this goal in mind Typical career path might be: – Insurance co insurance consulting firm establish own consulting firm – Pension consulting firm establish own pension consulting firm – Insurance Dept establish regulatory services consulting firm 8 Do you want a job with: No paid vacation? No pension plan? No health insurance benefits? No guaranteed income? Five bosses, each of whom wants something NOW? The potential to earn much more than you’re currently earning? Then self-employment might be the answer! 9 Advantages of Self- Employment Be your own boss Work at home/no commute time – Casual dress Flexible hours Good hourly rate Work from any location – Home is where the laptop is 10 Disadvantages of Self- Employment You may not like your boss “Work at home/no commute time” – Distractions at home – No social interaction with peers – No ability to learn from co-workers – Travel time to client location “Flexible hours” – Often chosen by client – you’re “on call” – May be 18 hours per day during a big project (no employees!) Good hourly rate – but no guaranteed hours 11 Disadvantages of Self- Employment No employee benefits – No paid vacation – No paid sick time – No pension plan – No health insurance Fixed expenses but variable income No employees to help with the work load Liability risks 12 Characteristics of Successful Self-Employed Actuaries Self-Motivated Defined Market Niche Strong Technical Skills Good Communication Skills Strong Sales Skills Broad Range of Industry Contacts Financially Prepared for Self-Employment Financially Disciplined 13 Self-Motivated Personal Example – Atlanta Olympics in 1996 – Office closed, worked at home My Solution: – Separate Office – Defined Office Hours – Dedicated Phone Line (Cell?) 14 Defined Market Niche What “product” will you sell? Hard to find work as a “generalist” “Specialists” find work assisting with special products – Special projects may have funding Underselling the competition doesn’t necessarily work 15 My Market Niche “Life Insurance Financial Reporting” – That’s too general Examples of specific “products” I sell: – Assistance with development, review, and assessment of effectiveness of controls in USGAAP financial reporting processes – Implementation of financial reporting valuation systems – Building and enhancing source of earnings analyses on universal life and annuity blocks of business – Actuarial audit support work to assist audit firms, state insurance departments, internal audit departments 16 Strong Technical Skills Expertise in subject matter – Specialize Good computer skills are a must – They don’t sell a project, but they’re necessary to complete the project – Microsoft products: Excel, Access, Powerpoint, Visual Basic, Word – Actuarial software – hands-on skills 17 Communication Skills Necessary for sales presentations Required for verbal communications during a project Critical when writing reports to document findings Start today to fine-tune your skills: grammar and spelling matter! 18 Sales Skills The best sales skills won’t help if you don’t have a good product to sell The best product won’t sell if you don’t have good sales skills Step one is to get in the door (the door of the decision maker) Many resources on effective sales techniques – read books now and develop sales skills Even if you are never self-employed, sales skills help you sell yourself and your ideas in any job 19 Industry Contacts Former Co-Workers Actuarial Meetings Actuarial Committees (SOA/CAS/AAA) Former Clients Cold Calls 20 Financial Preparation Expect Low Income First Few Years Significant Fluctuations in Cash Flow Start-Up Costs – Computer – Software (including Actuarial software) – Office Equipment – Office Furniture – Legal Fees to Establish Business (Costs of Incorporation) – Website – Marketing Literature – Office Rental (Optional) 21 Financial Preparation Fixed Costs – Insurance: Professional Liability & Business Insurance Medical, Disability & Life Insurance – Phone – Internet – Actuarial software – Actuarial Organization Membership Fees – Continuing Education Costs Other costs – Travel costs for sales calls – Travel costs for on-site work – Pension funding 22 Business Expenses: Insurance Professional Liability Insurance – $5,000+ per million coverage per year – Large companies often require consultants to carry coverage Business Owners Insurance – $1,000 - $2,000 per year – Large companies often require consultants to carry coverage Medical Insurance – Likely to be individual coverage – Requires underwriting – Rates vary with age/sex/heath/other – May be $10,000+ per year 23 Business Expenses: Other Actuarial software license (optional) – ~ $20,000 per year Society of Actuaries Dues (~$1,000) Academy of Actuaries Dues (~$1,000) Continuing Education – Meeting fee (~ $1,000) – Travel expenses (~ $1,000) Pension Plan – Various options available – Simplified Employee Pension (SEP) IRA – Solo 401K Subscriptions to literature (acctg, tax, law) 24 Test: Financially Prepared? Are you a good money manager? – Do you balance your checkbook? Are you a detailed-oriented bookkeeper? Do you have a budget which shows in detail what you make and what you spend? Do you have other sources of funds with which to support yourself in the early years of your new business? – Spouse’s income – Savings – Other ways to generate income (tutoring math, work for actuarial or finance temp agencies, other) 25 Test: Financially Disciplined? You find that your checking account balance is up to $20,000. You are most likely to: – A. Spend it – B. Project the amount needed to cover future cash flow requirements (estimate taxes, etc.) and spend the rest. – C. Save enough to cover future cash flow requirements and save the rest to cover future periods of lower cash in-flow. 26 Test: Financially Disciplined A. Likely to end up with IRS problems B. On the right track, but need to keep in mind that there are periods of “feast” and “famine”. C. Likely to succeed in the financial aspects of running a small business. 27 Recommendations Segregate business funds from personal funds: – Separate checking account – Separate credit card Reconcile business accounts monthly Bill clients monthly Never delay payment of estimate taxes Determine how to pay yourself: – A percentage of gross receipts? – A fixed amount per week or month? 28 Monthly Cash Flow Even if income is fairly regular, outflows are not. Insert graph here showing monthly cash inflows and outflows for CAC 29 SBA Small Business Association provides counseling, mentoring and training, and loans www.sba.gov 30 Ten Steps to Starting a Business (per SBA.gov) 1. Write a business plan 2. Get business assistance and training 3. Choose a business location 4. Finance your business 5. Determine legal structure Sole proprietorship Partnership Limited Liability Corporate (LLC) Corporation S Corp 31 Ten Steps to Starting a Business (per SBA.gov) 6. Register a business name with state government 7. Get a tax ID number 8. Register for state and local taxes State Tax ID Number Workers’ compensation Unemployment and disability insurance 9. Obtain business licenses and permits Federal, state and local licenses and permits 10. Understand employer responsibilities Legal steps you need to take to hire employees http://www.sba.gov/sba-direct/article/2815 32 Other SBA Resources Articles on self-employed and independent contractors Articles on minority-owned businesses Articles on woman-owned businesses Articles on veteran-owned businesses 33 Women and Minorities A number of larger companies have guidelines in place which require them to use minorities and women for 10% of their contract work Typically accomplished by requiring vendors to subcontract at least 10% of their work to woman-owned or minority owned businesses 34 Minority-Owned Business Sample contract from large bank: A “Minority-Owned Business” is a business that is at least 51 percent owned, and whose management and daily business operations are controlled, by one or more members of a socially and economically disadvantaged minority group — namely, U.S. citizens who are Black Americans, Hispanic Americans, Native Americans, Asian-Pacific Americans, or Asian-Indian Americans. 35 Woman-Owned Business Sample contract from large bank: A “Woman-Owned Business” is a business that is at least 51 percent owned by a woman (or women) who is a U.S citizen, controls the business by exercising the power to make policy decisions, and operates the business by being actively involved in its day-to-day management. 36 Woman/Minority Businesses To qualify as a Minority or Woman-Owned Business, the Business must be certified by an official certification agency acceptable to Company X. Vendor shall supply to Company X’s Vendor Diversity Group copies of official certification documentation. Vendor’s goal is to subcontract a minimum of 10% of the total dollar amount of this Agreement to Minority and Woman-Owned Businesses annually (the “Goal”). In order to balance Company X’s overall spending, the preferred allocation of the Goal is 7% to Minority Businesses and 3% to Woman-Owned Businesses. 37 Preparing to be a Self- Employed Actuary Pass actuarial exams Develop technical expertise Identify market niche Make industry contacts Develop sales and marketing skills Work for a consulting firm Pay off personal debts Save money 38 Getting Started as a Self- Employed Actuary Work for a consulting firm to learn the business: – Client development – Billing – Dispute resolution – Bidding projects – Develop base of contacts THEN: Buy a business or Start a business (self or partnership?) 39 Buying an Actuarial Consulting Firm Pay based on expected future revenues from existing clients – How to finance? Advantage is that there are existing clients Disadvantage is that clients may choose a different firm at sale Requires careful transition 40 Starting an Actuarial Consulting Business Advantage is no cash outflow to purchase business Disadvantage is that there are no clients initially 41 How to Set Billing Rate Convert former salary into hourly rate – may be lower bound Consider rates charged by larger consulting firms – May be upper bound Consider risks inherent in the project May accept lower rate on larger projects Rate may vary seasonally (supply/demand) – Audit firm rates higher January - March 42 Billing Issues Fixed fee engagements can be big risk – How to estimate hours – Double your initial estimate? – “The devil’s in the data” How to handle billing disputes Safer to bill periodically (monthly) rather than at project completion 43 Billing Files Maintain detailed records for personal records Time “clocked in” and “clocked out” in 15 minute intervals Task performed in each interval Cumulative hours per month Summarized statement sent to client 44 Unbillable Time Marketing – Sales calls – Website maintenance – Brochures – Writing articles, preparing presentations, brochures etc Administrative – Negotiating contracts – Drafting engagement letters – Preparation of proposals in response to government “RFP” – Insurance applications and updates – Computer issues – Monthly billing and bookkeeping – Estimate tax payments 45 More Unbillable Time Travel time Continuing education meetings Some actuaries adjust hours billed: – Factor adjustment when performing work for which the actuary is overqualified (e.g., adjust from FSA rate to ASA rate) – May not bill for “re-do” of work – May bill less after x hours per day – Very judgmental 46 Running a Small Business Consider need for clerical support May require tax or other accounting support May require technology support May require legal support 47 Technology Support Computer issues – – You are the help desk – Need good back-up systems – Need multiple computers – Need secure systems Phone issues – cell phone as business phone, quality issues? Internet issues – have a backup plan Can some of this be outsourced? 48 Tax/Accounting Support Consider engaging a tax accountant to assist with tax issues – LLC or partnership => likely to file multiple state tax returns – Partnership => special partnership tax forms – Self-Employment Tax – Quarterly Tax Estimates Consider engaging an accountant to assist with general bookkeeping (billing etc) 49 Legal Support Consider engaging an attorney to assist with: – Establishment of business (incorporation etc) – Drafting of engagement letters – Review of marketing materials – Review of contracts 50 Liability Risks Risk of Litigation – Mispriced insurance product – Products priced with tax issues (IRC 7702) – Perceived poor advice related to acquisition – Violations of confidentiality agreements – Issues related to assumptions in pension valuations Professional liability insurance amounts may not be adequate to cover a judgment Liability insurance may not cover sub- contractors 51 Employees vs Sub-Contractors? Employees typically require guaranteed income and benefits Employees create administrative burdens (benefits, workers’ comp, unemployment insurance) Subcontractors are paid only for hours worked Different subcontract can be selected for each project based on expertise required How to structure subcontractor agreement – “Subcontractor” has separate contract with client? – Subcontractor gets x% of amounts billed to client? – Subcontractor not paid until you are paid? Liability issues associated with subcontractors 52 Case Study A Background: Easing transition to – Several insurance consulting: company jobs – Spouse income – Consultant at – Prior consulting accounting firm experience Yrs in industry prior to Initial contacts: starting firm: ~15 – Extensive Market niche: Yrs as independent – Financial reporting consultant: 10+ – Audit support Current position: – Self-employed actuary 53 Words of Wisdom from A “Poor planning on your part doesn’t constitute an emergency on mine.” – Except that as a self-employed actuary, it does!!! A fail-proof “Get Rich Slow” scheme: “Spend less than you make.” My marketing strategy: “wait for the phone to ring” 54 Gross Revenue Percent per Month (2008 – 2011) 14% 12% 10% 8% 6% Revenue 4% 2% 0% Jan Mar May Jul Sep Nov 55 Bus Exp/Tax: Percent per Month (2008 – 2011) 30% 25% 20% 15% Expense 10% 5% 0% Jan Mar May Jul Sep Nov 56 Net Income: Percent per Month (2008 – 2011) 20% 15% 10% 5% 0% Net Income -5% -10% -15% Jan Mar May Jul Sep Nov 57 Case Study B Background: Easing transition to – Trained in Systems/IT consulting: before entering actuarial – Spouse income profession Initial contacts: – Several insurance company jobs – Limited Yrs in industry prior to Yrs as independent starting firm: ~10 consultant: 10+ Market niche: Current position: – Systems conversions – Self-employed actuary – Experience studies 58 Words of Wisdom from `B Represent yourself exactly as you are (good and bad both) Stay out of office politics 59 Case Study C Background: Easing transition to – CFO of large insurance consulting: company – Prior consulting – Partner in accounting experience firm – Savings & retirement Yrs in industry prior to plans starting firm: 20+ Initial contacts: Market niche: – Extensive – Group health insurance Yrs as independent – Litigation support consultant: ~10 – Specialist in “Patient Current position: Protection and – Self-employed actuary Affordable Care Act” 60 Words of Wisdom from C Financial (personal): – Financial planners generally suggest an emergency fund of 6 to 12 months. Suggest at least double that for a self-employed actuary (or, a working spouse) – Suggest minimal fixed costs (especially housing and debt) since income will almost certainly be very variable Bookkeeping: – Need QuickBooks are some other business software – Keep accurate records and separate personal from business expenses – Be prepared for payroll processing complications – even if you pay someone to process the forms. Incorporating/professional liability: – Will probably want to form a company – But cannot avoid professional liability – Choose between LLC, S-Corp, or C-Corp (advantages and disadvantages of each) – Probably want to purchase professional liability insurance – Hiring one person is a game changer 61 Words of Wisdom from C Pricing your services – Should try to find hourly rates that peers and large consulting firms are charging for type of consulting being considered – New jobs almost always take substantially more hours than you estimate but most companies will not give you a blank check (i.e. hourly rate without estimated hours) – “Annuity” type engagements (i.e. repetitive) are nice but rare for most actuarial consulting services. Also most price competitive – Responding to RFPs very time consuming and competitive Marketing – Very personal/individual as to what works, if anything (i.e. almost certain that word of mouth is best and requires having/getting a reputation) – A website, no matter how amateurish, is probably a must – Attending professional meetings is generally helpful. Opportunity to speak, network, and just let others know you are alive. – Referrals may be reciprocated Job performance – Client satisfaction a must – go the extra mile – Review Code of Professional Conduct and know what ASOP’s apply (see professional liability) – Every new job has enough wrinkles to make you uncomfortable (but must balance against being “too uncomfortable”) 62 Case Study D Background: Easing transition to – Several insurance consulting: company jobs – Spouse income – Consultant at Initial contacts: accounting firm – Moderate Yrs in industry prior to starting firm: ~10 Yrs as independent consultant: ~5 Market niche: Current position: – Pricing – Larger consulting firm – Financial reporting – Audit support 63 Case Study E Background: Easing transition to – Valuation Actuary at consulting: large insurance – Separation package company from prior employer Yrs in industry prior to Initial contacts: starting firm: ~20 – Limited Market niche: Yrs as independent – Financial reporting for consultant: < 5 variable annuities Current position: – Insurance Company 64 Case Study F Background: Easing transition to – Several insurance consulting: company jobs including – None one start-up company Initial contacts: Yrs in industry prior to – Moderate starting firm: ~10 Yrs as consultant: < 5 Market niche: Current position: – Financial reporting – Consulting firm – Reinsurance 65 Case Study G: Background: Easing transition to – AVP of Product consulting: Development for life – Revenue from insurance insurance company sales Yrs in industry prior to – Revenue from pension starting firm: 9 TPA Market niche: Initial contacts: – Initially: New product – Limited development for small Yrs as consultant: 30+ companies – Now: Mix of product Current position: development & financial – Owner of mid-sized reporting consulting firm 66 Words of Wisdom from G Be fully committed to making it work Put a lot aside for a rainy day Learn sales and prospecting skills – “G” worked with a group of agents while starting his consulting firm, allowing him to develop his sales skills 67 Case Study H Background: Easing transition to – Jobs at two life consulting: insurance companies: – Hired by former product development employer as consultant and financial reporting Initial contacts: Yrs in industry prior to – Fairly Limited starting firm: 10 Yrs as consultant: ~25 Market niche: – Initially: small to Current position: medium size companies – Self-Employed Actuary looking for good service Grew consulting at a low cost business to point that a larger firm bought – Actuarial temp services them out – Regulatory services Once again a self- employed actuary 68 Words of Wisdom from H During period of prosperity, keep on marketing. Service is your best asset. There is no better marketing than word of mouth testimony from your existing clients. Do not do work if you are not comfortable – either with your expertise or ability to do the work the right way or with your client. 69 Other Comments from H “I should have never succeeded, but I was too young to know that.” “Even as the firm grew, there were periods of famine. There were several months where my partner and I did not take a salary to make sure that there was sufficient cash to pay all the employees.” 70 Case Study I: Background: Easing transition to – Pension consultant two consulting: years – Joined firm as employee – Joined existing Initial contacts: insurance consulting firm – Firm’s existing clients – Became Partner, then Yrs as consultant: 30 Owner, of firm Current position: Market niche: – Owns consulting/TPA – Actuarial services for firm small life ins companies (pricing, valuation) – Migrated to third party administration work 71 Words of Wisdom from I “Words of wisdom are hard to come by.” “I have not done anything particularly brilliant, but have been presented with some decent opportunities and not screwed them up.” “It seems today you would have to start out with a larger consulting firm or company, learn the ropes and take your shot when you see the chance.” “Maintaining a consistent and broad base of clients is very difficult.” 72 What One “Big Four” Audit Partner Liked About a Large Firm Other actuaries and accountants to talk to Quality control – always someone to check/challenge what you're doing Range of expertise Variety of projects Ability to have large clients, internationally Clients on the forefront of issues – always interesting and challenging Ability to invest in development of service capabilities 73 What One “Big Four” Audit Partner Liked About a Large Firm Established infrastructure for: – Space – Administrative support – Graphics – Liability insurance – Human resources – Benefits – Technology – Legal 74 One Audit Partner’s View: Large vs Small Firm Benefits over small firm are: – Ability to do big projects for big clients in multiple, international locations – Integration with accounting and tax expertise Disadvantage is: – Cost (higher billing rates) 75 Character Traits of Successful Small Business Owners http://sbinformation.about.com/od/startingabusiness/tp/Character-Traits-Of- Successful-Small-Business-Owners.htm 1. Driven 6. Self-Reliant 2. Goal-Oriented 7. Humble 3. Confident 8. Resilient 4. Passionate 9. Focused 5. Budget-Minded 10. Open-Minded 76 Ten Traits Small Business Owners Need to Succeed http://ezinearticles.com/?Small-Business---Ten-Traits-All-Small- Business-Owners-Must-Have-To-Be-Successful&id=380025 1. Know Your Purpose 6. Be Prepared to Co- 2. Have a Desire To operate Succeed 7. Have the Will-Power 3. Have Faith that you to Go On can achieve what 8. Be habitual in all you you want need to do 4. Have a Clear Plan 9. Maintain the Quality 5. Have the Knowledge 10. Be 100% Persistent 77 Five Traits of a Successful Small Business http://www.investopedia.com/financial-edge/0910/6-Traits-Of-A- Successful-Small-Business.aspx#axzz203xccWR1 Cater to a Niche Market Get Cozy with Customers Be Flexible Focus on Skills Get Lucky 78 Top Ten Reasons Small Businesses Fail http://boss.blogs.nytimes.com/2011/01/05/top-10-reasons-small-businesses- fail/ 1. The math just doesn’t work – Not enough demand at a price that will be profitable 2. Owners who cannot get out of their own way 3. Out-of-control growth 4. Poor accounting 5. Lack of a cash cushion 79 Top Ten Reasons Small Businesses Fail (Continued) 6. Operational mediocrity 7. Operational inefficiencies Expenses too high 8. Dysfunctional management 9. Lack of a succession plan 10. A declining market 80 Question & Answer Time 81 Resources Smaller Consulting Section of SOA – 600 Members, mostly pension – Helps independent actuaries get resources from SOA – Provides training in presentations, etc. Small Business Association – sba.org SCORE (Service Core of Retired Executives) – score.org 82 Professionalism Self-employed actuaries need to understand and follow professionalism guidance issued by various actuarial bodies 83 Professionalism Revised Qualifications Standards Continuing Education Requirement for Professionalism Topics Professionalism Topics Incorporated into Actuarial Meetings Web-Based Professionalism Presentations Life & Health Qualification Seminar Contingencies Articles on Professionalism 84 US Hierarchy of Professional Stds Code of Professional Conduct Actuarial Standards of Practice (ASOPs) Applicability Guidelines – For various tasks routinely performed by actuaries, which ASOPs normally apply – Organized by Specialty (Casualty, Health, Life, Pension) Practice Notes Discussion Papers 85 Code of Professional Conduct Effective January 1, 2001 Applies to all Academy Members Identifies responsibilities actuaries have to: – The public – Their clients and employers – The actuarial profession Practice Only When Qualified Divided into various “Precepts” Full text at http://www.actuary.org/pdf/prof/code_of_conduct.pdf 86 Precept 1: Professional Integrity “An actuary shall act honestly, with integrity and competence, and in a manner to fulfill the profession’s responsibility to the public and to uphold the reputation of the actuarial profession.” 87 Precept 2: Qualification Standards “An Actuary shall perform actuarial services only when the Actuary is qualified to do so on the basis of basic and continuing education and experience, and only when the actuary satisfies applicable qualification standards.” – Refer to “Qualification Standards for Actuaries Issuing Statements of Actuarial Opinion in the United States”, effective January 1, 2008 – Can result in expulsion, suspension, reprimand 88 Precept 3: Standards of Practice “An Actuary shall ensure that Actuarial Services performed by or under the direction of the Actuary satisfy applicable standards of practice.” – Homework: Read all current and proposed ASOPs at “http://www.actuarialstandardsboard.org/asops. asp” 89 Actuarial Standards of Practice (ASOPs) Provides Framework for performing actuarial assignments Offers guidance on relevant issues; captures acceptable practices, documentation, and disclosure Plenty of room for actuarial judgment; not narrowly prescriptive 90 Actuarial Standards of Practice (ASOPs) 45 ASOPs Most recent is #45: “The Use of Health Status Based Rish Adjustment Methodologies” Widely Applicable: – #23 Data Quality – #41 Actuarial Communications Exposure Drafts Discussion Drafts (precede exposure drafts) 91 Precept 4: Communication and Disclosure “An Actuary who issues an Actuarial Communication shall take appropriate steps to ensure that the Actuarial Communication is clear and appropriate to the circumstances and its intended audience, and satisfies applicable standards of practice.” 92 Precept 5: Communication and Disclosure “An Actuary who issues an Actuarial Communication shall, as appropriate, identify the Principal(s) for whom the Actuarial Communication is issued and describe the capacity in which the Actuary serves.” 93 Precept 6: Communication and Disclosure “An Actuary shall make appropriate and timely disclosure to a present or prospective Principal of the sources of all direct and indirect material compensation that the Actuary or the Actuary’s firm has received, or may receive, from another party in relation to an assignment for which the Actuary has provided, or will provide, Actuarial Services for that Principal. The disclosure of sources of material compensation that the Actuary’s firm has received, or may receive, is limited to those sources known to, or reasonably ascertainable by, the Actuary.” 94 Precept 7: Conflict of Interest “An Actuary shall not knowingly perform Actuarial Services involving an actual or potential conflict of interest unless: (a) the Actuary’s ability to act fairly is unimpaired; (b) there has been disclosure of the conflict to all present and known prospective Principals whose interests would be affected by the conflict; and (c) all such Principals have expressly agreed to the performance of the Actuarial Services by the Actuary.” 95 Precept 8: Control of Work Product “An Actuary who performs Actuarial Services shall take reasonable steps to ensure that such services are not used to mislead other parties.” 96 Precept 9: Confidentiality “An Actuary shall not disclose to another party any Confidential Information unless authorized to do so by the Principal or required to do so by Law.” 97 Precept 10: Courtesy and Cooperation “An Actuary shall perform Actuarial Services with courtesy and professional respect and shall cooperate with others in the Principal’s interest.” 98 Precept 11: Advertising “An Actuary shall not engage in any advertising or business solicitation activities with respect to Actuarial Services that the Actuary knows or should know are false or misleading.” 99 Precept 12: Titles and Designations “An Actuary shall make use of membership titles and designations of a Recognized Actuarial Organization only in a manner that conforms to the practices authorized by that organization.” 100 Precept 13: Violations of the Code of Professional Conduct “An Actuary with knowledge of an apparent, unresolved, material violation of the Code by another Actuary should consider discussing the situation with the other Actuary and attempt to resolve the apparent violation. If such discussion is not attempted or is not successful, the Actuary shall disclose such violation to the appropriate counseling and discipline body of the profession, except where the disclosure would be contrary to Law or would divulge Confidential Information.” 101 Precept 14: Violations of the Code of Professional Conduct “An Actuary shall respond promptly, truthfully, and fully to any request for information by, and cooperate fully with, an appropriate counseling and disciplinary body of the profession in connection with any disciplinary, counseling, or other proceeding of such body relating to the Code. The Actuary’s responsibility to respond shall be subject to applicable restrictions on Confidential Information and those imposed by Law.” 102