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Underfunded whole life insurance may have only performed 4%. However, designed with additional premiums they have actually earned closer to 7% in the 30 years from 1984-2013. Even during the period between 1977 and 1982 where interest rates shot through the roof and bond holders didn’t recapture their losses for several years, over funder whole life returned 35% after the cost of insurance is considered.

The insurance company calculates the policy prices (premiums) at a level sufficient to fund claims, cover administrative costs, and provide a profit. The cost of insurance is determined using mortality tables calculated by actuaries. Mortality tables are statistically based tables showing expected annual mortality rates of people at different ages. Put simply, people are more likely to die as they get older and the mortality tables enable the insurance companies to calculate the risk and increase premiums with age accordingly. Such estimates can be important in taxation regulation.[10][11]
But here is the key: the most astute line in the article is “If you have a large amount of money, have already maxed out all of your tax-deferred savings, and you can afford to front-load your policy with large payments in the first several years, it can provide better returns than was discussed above. It is a useful product in a limited number of cases.”
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I am a fairly wealthy Canadian professional with a corporation. I have indeed maxed out all my tax-deferred savings options. I am nearing 50 years old. I only have one child. By the time I retire I will probably have more money than I could use , but my daughter will probably already inherit more money than she will ever need when I pass away. Do I bother with all of this complicated permanent insurance stuff, or just forget it and try to spend as much as I can ?!! Your article makes me want to forget the whole thing is I am not usually comfortable investing in things I don’t understand very well especially when everyone seems to be pushing it due to high commissions. However I seem to be in that 1% group you say would actually benefit from this. What do you think?
I’m glad those policies worked out for you, and I agree that the simple act of saving money is more important than the specific investments you choose, especially at the beginning. With that said, it’s also a good idea to invest that money as efficiently as possible and I do not think that whole life insurance provides that efficiency for the vast majority of people.
Definite loss: The loss takes place at a known time, in a known place, and from a known cause. The classic example is death of an insured person on a life insurance policy. Fire, automobile accidents, and worker injuries may all easily meet this criterion. Other types of losses may only be definite in theory. Occupational disease, for instance, may involve prolonged exposure to injurious conditions where no specific time, place, or cause is identifiable. Ideally, the time, place, and cause of a loss should be clear enough that a reasonable person, with sufficient information, could objectively verify all three elements.

Of course, it’s always more efficient to just save the money themselves. However, many people don’t and people often want to make sure that the money will be there when they are old and can no longer make decisions for themselves. Whole life is one way to do that. We chose term because it made more sense for us and it was so cheap since we were young when we bought. However, I’m just presenting the alternate viewpoint coming from someone who has filed many, many whole life policies on behalf of grateful families.
Virtually every state mandates that insurance agents and brokers meet licensing requirements, which normally entails the successful completion of a written examination. Prelicensing educational requirements may also apply, which can vary depending on the state and license type. Separate licenses are necessary for each line of insurance, including Life and Health and Property and Casualty. In addition, agents and brokers may have to meet ongoing continuing education requirements to maintain their licenses.

Mores also gave the name actuary to the chief official—the earliest known reference to the position as a business concern. The first modern actuary was William Morgan, who served from 1775 to 1830. In 1776 the Society carried out the first actuarial valuation of liabilities and subsequently distributed the first reversionary bonus (1781) and interim bonus (1809) among its members.[7] It also used regular valuations to balance competing interests.[7] The Society sought to treat its members equitably and the Directors tried to ensure that policyholders received a fair return on their investments. Premiums were regulated according to age, and anybody could be admitted regardless of their state of health and other circumstances.[9]


That’s a great point. While flexibility can certainly be helpful, these policies are often sold as if they will help you achieve all of your financial goals. And while in the right situations they can be available for multiple needs, they are still a limited resource and can, in the end, typically only be used for one thing (or a couple of things on a small basis).
Each type of life insurance product has its advantages and disadvantages. You can’t say term life is the best, whole life is the best or universal life is the best. It depends on what an individual client need and his or her situation. As a client, they should know all the advantages and disadvantages but of course, they are under the supervision of a certain type of insurance agent that can be biased and try to sell what they have to offer to form their companies. Avoid an agent that focuses on selling one type of product. Talk to an agent who can provide the knowledge of each type and you can choose what best for you.

True, but what’s not accounted for is the rolling geometric average. Trailing returns only assume you invest at the beginning of a period and hold to the end. The rolling average (if done correctly) assumes you invest over time…say monthly…like almost everyone does. I remember reading several pieces by Dan Wiener (who is an advocate for index fund investing, and specifically Vanguard) mention this.
Like any other type of insurance, you're in control of your life insurance policy. You determine how much coverage you need (from $50,000 up to a $1 million policy), how long you need it, who's covered and when you make your payments (called premiums). Usually, you can choose to pay monthly, annually or quarterly for 10, 20, 30 years or over your lifetime to maintain the coverage. When you die, if your policy is still active, the people you've listed on your policy (called your beneficiaries) get paid the death benefit. In most cases, this payment is paid in one lump sum to an individual or family.
A few comments… You shouldn’t ever be buying whole life insurance for purely for the reason of investing, you buy any life insurance because you need life insurance, the investment component is secondary. So not sure why we are analyzing it purely as an investment (I actually do know why, because some agents try to sell it this way, and Matt is trying to help them avoid a pitfall).

“In the policy that was attempted to be sold to me, the “guaranteed return” was stated as 4%. But when I actually ran the numbers, using their own growth chart for the guaranteed portion of my cash value, after 40 years the annual return only amounted to 0.74%. There are a number of explanations for this difference, including fees and the way in which the interest rate is applied.”


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In India IRDA is insurance regulatory authority. As per the section 4 of IRDA Act 1999, Insurance Regulatory and Development Authority (IRDA), which was constituted by an act of parliament. National Insurance Academy, Pune is apex insurance capacity builder institute promoted with support from Ministry of Finance and by LIC, Life & General Insurance companies.
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It is wise to note that as a business owner or individual that the cash values of WLI can serve as collateral (via assignment) when otherwise collateral may not be available. This can help greatly with loan rates that may be needed in the future for a variety of reasons. Banks realize they are protected against insolvency, liens, and lawsuits (another benefit of WLI) ( yes trusts can do this but why pay 8-15k in legal fees to structure them).

Death benefits are generally received income tax-free by your beneficiaries. In the case of permanent life insurance policies, cash values accumulate on an income tax-deferred basis. That means you would not have to pay income tax on any of the policy’s earnings as long as the policy remains in effect. In addition, most policy loans and withdrawals are not taxable (although withdrawals and loans will reduce the cash value and death benefit).2

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In the United States, brokers are regulated by the state (or states) in which they work. Most brokers are required to have an insurance broker license, which involves taking courses and passing an examination. Each state has different requirements for insurance brokers, which a broker must meet to be licensed in that state. Most states require insurance brokers to take continuing education courses in order to maintain their license.
Naturally, the float method is difficult to carry out in an economically depressed period. Bear markets do cause insurers to shift away from investments and to toughen up their underwriting standards, so a poor economy generally means high insurance premiums. This tendency to swing between profitable and unprofitable periods over time is commonly known as the underwriting, or insurance, cycle.[25]
Now, it turns out that we have higher, broader family obligations than I anticipated 20-27 years ago. My wife and I plan to possibly keep working past 65 (which I hadn’t anticipated) and would like to be able to fund these obligations even if we were to die before our now planned time to stop working (that goes past the periods anticipated by the terms of our term policies). Our term policies and term coverage are beginning to expire and due to certain issues, at best, we would have to pay very high premiums for anything I would try to purchase now, if we would qualify at all.

If you need life insurance (which in order to find out , you must ask yourself one question : am I going to die ?) a Whole Life Insurance policy is a non-risky , non-volitile way of earning a high rate of return with a very conservative risk portfolio. A whole life policy is part of a healthy financial portfolio. It grows with preferential tax treatment and pays tax free to your beneficiary or estate. In nearly every case of par Whole life if you are under 50 you will have a cash surrender value equal to 100% and up to 800% of the premiums paid.
Hey Mark. Thanks for the kind words and you make a great point! That’s a big reason for #5 in the article. With the speed at which life can change, locking yourself into paying those premiums for decades is just so limiting. And you go even further than that here with simply wanting to invest the money you’ve already put in differently, and I couldn’t agree with you more. It adds a lot of inflexibility to your planning which can make figuring out the other pieces a lot more difficult.
I really wish you would have stated more clearly the difference between the typical whole life plans with zero overfunding and a participating overfunded whole life policy. But I agree with you: What’s the point of not overfunding? Those policies have such a low cash component that they typically are just a ploy to make money by the agent and it seems as if that was your point all along. Which you should have clarified. Why minimum whole life insurances plans are a scam, especially when sold as a main investment vehicle. But then a little drama drives traffic right?
Did someone say convenient? Life can be complicated, which is why we make insurance so easy. Our customer service is accessible and personal. You can choose from different payment options, and you’re able to manage your account online for anytime, anywhere access. Just in case you want to view your policy at 2 a.m. while on vacation. Not that you would, but you could.
There are a number of explanations for this difference, including fees and the way in which the interest rate is applied. But the bottom line is that you can’t take that “guaranteed return” at face value. It is incredibly deceptive. Run the numbers for yourself and see if you’re happy with the result. The reality is that you can often get better guaranteed returns from a savings account or CD that’s also FDIC insured.
Still, although I believe that persons without adequate income either to fund adequately retirement vehicles or to pay monthly bills without using a home equity line of credit or leaving any credit card balances unpaid, should probably only purchase term insurance, if you earn more than that, I am thinking that purchasing 15% to 25% of needed life insurance coverage though whole life policies may be a way to mitigate against the needed guessing that goes into picking the length and amount of term policies. Do you agree?
I would 100% agree that whole life doesn’t yeild a great return and in most cases is used inappropriately. With that being said, for the right individuals it is in fact a great product. It can not only be used as a rich mans ira, but also a vehicle to max out pensions, and a great was to save money for college without disqualifying the student for financial aid.
They cannot provide you with any final answers. Calculators only allow you to perform "hypotheticals," recalculating and generating new results as you make and input new assumptions. Using these tools and educating yourself on the workings of life insurance and other financial products, however, can help you feel more comfortable when discussing your needs with professionals like a New York Life agent.
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Underfunded whole life insurance may have only performed 4%. However, designed with additional premiums they have actually earned closer to 7% in the 30 years from 1984-2013. Even during the period between 1977 and 1982 where interest rates shot through the roof and bond holders didn’t recapture their losses for several years, over funder whole life returned 35% after the cost of insurance is considered.
As for your question, I don’t believe I’ve ever reviewed a USAA whole life policy so I can’t comment on then specifically. I would simply encourage you to start by clarifying your personal goals and to then evaluate each option based on how well it will help you meet them. With that said, of your main goal is investing for retirement then I would typically encourage you to max out traditional retirement accounts before considering any kind of life insurance.
Your premise is that whole life insurance is a bad investment. Fine, however, it is not a bad purchase. It is insurance and when thinking about the defined purpose of insurance then it can be a different story. Your electric service is a bad investment but think of the difficulty in living without electricity. Sure you could invest the bill amount each month into a nice Roth IRA but we seek the benefits of the service and willingly pay the bill. I suggest that people look at insurance the same. In my case and for my intent, whole life insurance was prudent. Like any car lease deal or stock purchase, there can be good and bad deals; one should not declare all forms at all points in time to be definitive. I gifted my child a whole life policy. The rates for a young person are as good as they get; she will never have insurance bills nor be without insurance. There is much left to explain but in short her $25,000 baby policy is growing $1,000 per yea. She will never have to pay a premium but will have $225,000-$350,000 payout one day while providing some protection also during the income/mortgage/child rearing adult years because I purchased it for her at the cost of $120.25 per year! No way could a poor farm kid without inheritance or wealth and limited income but high student loan debt create that kind of wealth for his children in the immediate or most vulnerable time period. To leave her in the same boat, as my parents did, is in no way wealth building. I got married and had mortgage, student loans, and large term life insurance bills because to go without any seemed irresponsible having no wealth but whole life was too expensive. So yes, it is far from a great investment but it is the most responsible gift I ever gave my child. It will not depreciate like a car and it is more certain than lottery tickets! Could I really produce that protection for her with liquidity via investing for only $120 per year? Tip: an insurance agent once told me (he should not have mentioned it) they have NEVER paid out on a life insurance policy because people always eventually let them expire and quit paying on them. Rates are so cheap for young healthy people because they are not likely to die. So this is also an exercise in discipline and responsibility not just finding the right stream to pan for gold.

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Defense Base Act (DBA) insurance provides coverage for civilian workers hired by the government to perform contracts outside the United States and Canada. DBA is required for all U.S. citizens, U.S. residents, U.S. Green Card holders, and all employees or subcontractors hired on overseas government contracts. Depending on the country, foreign nationals must also be covered under DBA. This coverage typically includes expenses related to medical treatment and loss of wages, as well as disability and death benefits.
Thanks for the insightful article. I agree with the general statement that, in a vacuum, it is better to “buy term and invest the difference.” However, I’m interested to hear your thoughts on using whole life insurance as an investment vehicle in the context of the infinite banking model (assuming you are familiar with the concept). From what I understand, it sounds like a good way to achieve predictable and guarenteed growth on a compounded basis while allowing you to borrow money from your own policy and pay yourself the interest, all while always having access to the funds. I think it might be wise for people, like myself, are looking for guaranteed growth with little risk.
These reviews are all from Medicare beneficiaries just like you. Our clients consistently rate us 5 stars for both our up-front help, but also the phenomenal back-end support you get from our Client Service Team. We have some of the very best Medicare supplement agents in the country. These independent Medicare advisors truly care. You can read our reviews here. Notice how many of them are from clients who called us when Medicare denied their claim or rejected their bills or their doctor mis-codes a service or when they are standing at the pharmacy and can’t get their medication. Normally you would call the insurance company yourself to try to figure out how to fix these things.
After insurance has been selected and purchased, most insurance brokers will continue to provide service to their clients. This includes advising clients on technical issues that may be helpful in the event that a client has to file a claim, helping clients decide if they should change their insurance policies or coverage, and even making sure that clients comply with their policy’s requirements.
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Life insurance is designed to provide families with financial security in the event of the death of a spouse or parent. Life insurance protection can help pay off mortgages, help provide a college education, help to fund retirement, help provide charitable bequests, and, of course, help in estate planning. In short, if others depend on your income for support, you should strongly consider life insurance.
Hi Matt – my 3 kids (now all in their 20’s) had whole life policies opened for them by Grandpa 20 years ago. He has been paying a fixed annual payment of $240, but it’s now up to me (the kids are just starting out and don’t have a cent to spare). My first thought is to have them cancel and take the cash value (~7k each), but in looking at the policies (for the first time) it looks like at this point they are getting a decent cash value return – each of the last 3 years it’s been about 4.2% PLUS the $240. AND the dividend the last few years has been almost as much as the annual payment – but has been buying more insurance (that they don’t need). Is it possible that if you suffer through the first 20 years, it then becomes a good investment? especially if I redirect the dividends to the cash value or a premium reduction? Great article by the way.
Like most small business owners, you probably purchase your insurance policies through an insurance agent or broker. The functions performed by insurance agents are similar, but not identical, to those performed by brokers. This article will explain how they differ. It will also explain how agents and brokers make money from the premiums you pay your insurers. Except where noted, the following discussion applies to agents and brokers selling property/casualty insurance.
Mores also gave the name actuary to the chief official—the earliest known reference to the position as a business concern. The first modern actuary was William Morgan, who served from 1775 to 1830. In 1776 the Society carried out the first actuarial valuation of liabilities and subsequently distributed the first reversionary bonus (1781) and interim bonus (1809) among its members.[7] It also used regular valuations to balance competing interests.[7] The Society sought to treat its members equitably and the Directors tried to ensure that policyholders received a fair return on their investments. Premiums were regulated according to age, and anybody could be admitted regardless of their state of health and other circumstances.[9]

With that said, yes the interest rates are good, but it’s not really appropriate to compare the interest rate on a whole life loan to interest rates from other sources. With whole life, you’re borrowing YOUR OWN money that you already contributed after-tax. That’s very different from borrowing from a bank, where the money was never yours. It’s much more appropriate to compare the long-term, cumulative interest rate to the long-term after-tax returns you could get from other investments. That comparison looks very different and often much less beneficial for whole life.


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When the market experiences “down years” you will want to used a fixed investment to take your distributions in order to give your market-exposed vehicles time to recoup losses. This is one of the best pieces I have seen regarding “Taming a Bear Market” where one uses whole life insurance to supplement 401(k) distributions in bad years: http://www.becausewearewomen.com/documents/LEGACY10-RETIREMENTSUPP.pdf
As far as buying term and investing the difference the company I bought from has produced far better risk adjusted returns when compared to my analysis over the last twenty years of buying term and investing the difference in the S&P. I don’t mean to say we should not invest but I view my permanent policy as a great place to take some risk off the table and also to have some long term safe dollars. I agree that unless you die early, this is not a good short term idea. Also the fact that is not considered an asset as you mention, gives it very favorable treatment. I asked myself, if I were a beneficiary would I want to inherit a portfolio worth 2.5 million a house worth a million or a 3.5 million tax free check. For me, it was the latter. For high net worth people I would argue it is better than a muni allocation. I don’t view the discussion as one or the other invest and buy term or just buy whole life but rather as a synergy of assets that can produce a great value. As you say, it’s all quite subjective. Is whole life your best “investment”? No, but I do think it is a fantastic tool.
You’re right, there is a guaranteed portion of these policies. And like I say in the post, that guaranteed portion is nowhere near the illustrated return and is much less attractive than how it’s presented (e.g. a 4% “guaranteed” return is not actually anywhere near 4%). So to say that there’s a guarantee and somehow equate that to the numbers you presented earlier is, in my mind, misleading.
What will you need the life insurance for at that point? Would you be able to save $10,000 in a savings account between now and age 70 instead of paying for whole life insurance? If you take the $26.50 difference in premiums that you mention here and put it into a savings account each month, you’ll have about $7,782 by age 70, assuming 1.5% interest. If you can increase that monthly contribution to $34.25, you’ll reach just over $10,000 by age 70. And that money will be available for whatever you or your family need, any time you want.
You don’t have to be an expert to get a good deal on your insurance premiums -- that’s what we’re here for. Whether it’s auto, home, life or health insurance, and no matter what stage of life you’re in, we can educate you on how insurance works to protect you, your family and your assets. We also break down how pricing works, explain how much insurance you need for your particular situation and guide you through the buying process so you can be sure you’re getting the best deal on the right policy.
If you need life insurance (which in order to find out , you must ask yourself one question : am I going to die ?) a Whole Life Insurance policy is a non-risky , non-volitile way of earning a high rate of return with a very conservative risk portfolio. A whole life policy is part of a healthy financial portfolio. It grows with preferential tax treatment and pays tax free to your beneficiary or estate. In nearly every case of par Whole life if you are under 50 you will have a cash surrender value equal to 100% and up to 800% of the premiums paid.
Special exclusions may apply, such as suicide clauses, whereby the policy becomes null and void if the insured commits suicide within a specified time (usually two years after the purchase date; some states provide a statutory one-year suicide clause). Any misrepresentations by the insured on the application may also be grounds for nullification. Most US states specify a maximum contestability period, often no more than two years. Only if the insured dies within this period will the insurer have a legal right to contest the claim on the basis of misrepresentation and request additional information before deciding whether to pay or deny the claim.
I certainly don’t think that an insurance policy has to pay out to be valuable and that isn’t necessarily what I meant. We have term insurance now and I certainly find value in it even though it (hopefully) will never pay. What I meant was that the value to other family members is immeasurable. I can’t tell you how many times that I’ve seen a whole life policy swoop in and save the day when family members were struggling to cover the cost of a $10,000 or more funeral. I’ve just seen it happen too many times. Nobody thinks their 90 year old mom whose been in a nursing home for ten years would have life insurance and trust me when I say that people are pleasantly surprised when they find out that that’s the case.
Beyond that, I do agree that whole life insurance can be useful in certain situations when structured properly. But those situations are few and far between and they require the help of someone who both knows the ins and outs of these policies AND is willing to put the client’s interests over their own financial interests (i.e. minimizing commissions and other costs on the policy). That kind of person is also difficult to find.
Insurers will often use insurance agents to initially market or underwrite their customers. Agents can be captive, meaning they write only for one company, or independent, meaning that they can issue policies from several companies. The existence and success of companies using insurance agents is likely due to improved and personalized service. Companies also use Broking firms, Banks and other corporate entities (like Self Help Groups, Microfinance Institutions, NGOs, etc.) to market their products.[26]

My parents had been paying into a whole life policy for many years and did not pay much attention to the cash balance over that time. When they finally had evaluated what they had in the policy, they discovered the ‘cost of insurance’ on the now older policy had increased so much that the premium they had been paying no longer covered the costs of the policy and the balance needed was being withdrawn FROM THEIR CASH VALUE. Needless to say, the insurance company or their agent did not notify them of this, so a policy that they had paid $75,000 into had a cash value of just $12,000 and was actually decreasing in value. Whole life policies are advertised as you paying the same premium amount for the entire life of the policy, but in the small print they are apparently allowed to adjust for the ‘cost of insurance’. It’s a brilliant scam. Pay attention to the policies you have.
Advanced economies account for the bulk of global insurance. With premium income of $1.62 trillion, Europe was the most important region in 2010, followed by North America $1.409 trillion and Asia $1.161 trillion. Europe has however seen a decline in premium income during the year in contrast to the growth seen in North America and Asia. The top four countries generated more than a half of premiums. The United States and Japan alone accounted for 40% of world insurance, much higher than their 7% share of the global population. Emerging economies accounted for over 85% of the world's population but only around 15% of premiums. Their markets are however growing at a quicker pace.[40] The country expected to have the biggest impact on the insurance share distribution across the world is China. According to Sam Radwan of ENHANCE International LLC, low premium penetration (insurance premium as a % of GDP), an ageing population and the largest car market in terms of new sales, premium growth has averaged 15–20% in the past five years, and China is expected to be the largest insurance market in the next decade or two.[41]

Your comment on term insurance allowing you to convert at anytime is inaccurate. You must read the conversion language as it is designed to protect the insurance company. Met life for example states ” During the conversion period shown in the policy schedule you can convert this policy, while it is in force with all premiums paid, to a new policy–On a plan of permanent insurance, with a level face amount, available on the policy date of the new policy.”. Some term plans won’t let you convert after 10 years or if your over age 65. Imagine having a 20year $1,000,000 term plan and getting cancer in the 19th year. You want to convert but find out the conversion period ended in the 10th year. Also, the company typically determines which plan you can convert to. Maybe its just 2 plans out of the 8 they offer. What is the likelyhood of those being the best 2 plans available? Alas, no one reads the contract or the prospectus for that matter. My dad always said “the big print givith and the small print taketh away.”

As for your question, USAA is a fantastic company and I would happily recommend them for many things, like auto, home, and umbrella insurance. With that said, I have never reviewed one of their whole life insurance policies and therefore can’t really comment on that specifically. I will say that I would be careful about taking that 4.5% return at face value, as I describe in the post. I would encourage you to run the numbers for yourself to see what it really comes out to.
The Business Benefits Group is a full-service agency offering affordable, comprehensive insurance strategies for businesses. Our aim is to protect your assets by providing professional risk-management solutions. Whether you are a new or established business, you need the right type of insurance to protect your interests. When you contact BBG regarding our business insurance services, we will determine the best plan for you according to the needs of your business, the number of staff you have, risks that you may be facing, and similar factors. Call our office today to learn more about how we can protect your business or request a consultation online.
Thanks for reaching out Bob. There’s a lot that goes into this decision with the position that you’re in, and the right choice really depends on your personal financial situation and what you’re trying to achieve. I would lean towards trusting the advice of an advisor who doesn’t get paid to sell whole life, since that advice is likely to be more objective. It sounds like you’re already working with a couple of advisors, but if you’d like another opinion I would search NAPFA and/or Garrett Planning Network to find a fee-only financial planner in your area.
The cost of other types of life insurance varies greatly, depending on how much you buy, the type of policy you choose, the underwriter's practices, and how much commission the company pays your agent. The underlying costs are based on actuarial tables that project your life expectancy. High-risk individuals, such as those who smoke, are overweight, or have a dangerous occupation or hobby (for example, flying), will pay more.
Muslim scholars have varying opinions about life insurance. Life insurance policies that earn interest (or guaranteed bonus/NAV) are generally considered to be a form of riba[60] (usury) and some consider even policies that do not earn interest to be a form of gharar (speculation). Some argue that gharar is not present due to the actuarial science behind the underwriting.[61] Jewish rabbinical scholars also have expressed reservations regarding insurance as an avoidance of God's will but most find it acceptable in moderation.[62]
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For example, most insurance policies in the English language today have been carefully drafted in plain English; the industry learned the hard way that many courts will not enforce policies against insureds when the judges themselves cannot understand what the policies are saying. Typically, courts construe ambiguities in insurance policies against the insurance company and in favor of coverage under the policy.

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