4. If you end up wanting permanent life insurance when you get older, you have plenty of options other than buying whole life insurance as an investment when you’re young. You could convert a term policy. You could buy guaranteed no-lapse universal life. There are plenty of options that don’t require you lock yourself into a poorly-performing policy at a young age when that cash flow would be better used elsewhere.

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Nick this was a terrific overview. You didn’t mention the whole life rip-off, i.e., that the Client is paying for 2 things but in the end only gets 1. If the insured dies the death benefit goes to the beneficiary, the cash goes back to the company. Conversely, if the Client takes the cask the contract is terminated and the death benefit is gone. Bad, bad, bad!

2) With a portfolio of risky assets, the LONG-TERM RETURN is expected to be higher, but the variability around that is MUCH higher. In pretty much all of the “expected return” analyses that people on the internet show to compare whole life to term life + investing the difference, they are just comparing annualized returns or an IRR on a zero-volatility return stream. What they don’t account for are situations where the market crashes and you panic, wanting to move money into cash, or having to draw down on assets because they’re liquid and you can. This is normal behavioral stuff that occurs all the time, and reduces the power of your compounding. If you and your adviser are sure you can avoid these common pitfalls, then that is great and you might want to go for it. But don’t dismiss the reality. Also when running your simulations, make SURE to tax all of your realized capital gains and interest income along the way, and unrealized cap gains at the end. It can make a big difference.

Brokers are often able to get better rates on insurance policies for their clients than individuals buying insurance directly from the company. That is because insurance companies know that brokers have the experience to guide their clients to the right policies with the proper level of coverage. Policyholders who used brokers are less likely to make unnecessary claims or to be under insured, which ultimately saves the insurance companies money. The companies usually offer special broker pricing as a result — so that broker clients have lower cost options available to them. While agents may also get special pricing, they are working for the insurance company — not for you. A broker can offer a range of quotes from different insurers to give clients options that fit their needs and their budgets. This ability to shop for the best prices from a number of carriers typically saves clients who use brokers money.
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Response 3: I’m sure that some are. It is up to you who to trust. I’d suggest asking up-front how these people are paid, because some are non-commissioned (e.g. if your employer pays them a flat fee to consult). But also keep in mind that you don’t want to take your advice from people with the opposite bias, either. Financial advisers are often paid on discretionary assets managed. If they are, then their incentive is clearly for you to buy term insurance (or no insurance) and let them invest as much as possible on your behalf. Just be careful and take a long time to think through the issues.
Dealing with an insurance broker as opposed to directly with an insurer is something many customers (particularly businesses) choose to do in Australia for reasons including: the ease of having the "shopping around done for them"; having the opportunity for premium funding which allows for larger insurance policies to be paid in installments rather than all at once; dealing with one broker for all policies from the car insurance to professional indemnity insurance rather than dealing directly with several insurers; and, the ease of having claims managed by the broker who deals directly with the insurer on the client's behalf.

There are also companies known as "insurance consultants". Like a mortgage broker, these companies are paid a fee by the customer to shop around for the best insurance policy amongst many companies. Similar to an insurance consultant, an 'insurance broker' also shops around for the best insurance policy amongst many companies. However, with insurance brokers, the fee is usually paid in the form of commission from the insurer that is selected rather than directly from the client.
The person responsible for making payments for a policy is the policy owner, while the insured is the person whose death will trigger payment of the death benefit. The owner and insured may or may not be the same person. For example, if Joe buys a policy on his own life, he is both the owner and the insured. But if Jane, his wife, buys a policy on Joe's life, she is the owner and he is the insured. The policy owner is the guarantor and he will be the person to pay for the policy. The insured is a participant in the contract, but not necessarily a party to it.
Most people are familiar with or have worked with an insurance agent at some point in their lives. However, a broker has an entirely different role from an insurance agent. Unlike insurance agents, insurance brokers do not work for an insurance company. They work for their clients, providing advice on the best insurance options for their clients’ needs. Their goal is to support their clients’ interests — not to sell a particular policy on behalf of an insurance company.
Thanks for reaching out Kendra. To be quite honest this is a complicated question without a simple answer. It depends very much on your father’s need for life insurance, his current health status, and the specifics of this policy. It may very well be that the policy you have is your best option going forward. Or it may be that there’s a better one. But it’s impossible to know without a more thorough evaluation.
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.
With that out of the way, I’ll point out that I would not even consider selling my best friend whole life. It’s a rip-off in his hands and I value my friendships too strongly to alienate those I love by selling them whole life. I would however sell it to my wife! Why is that? Well, because the commissions on these policies are HUGE. Between the First Year Commission and the override, if I buy the policy for myself or my wife and just roll the commission into additional whole life, it begins to look attractive. That compounding makes it attractive for insurance salespeople in a way that is simply not available for the average consumer. So when your insurance guy says “oh yeah, I own this policy” it’s probably true…but the value proposition is very different for each of you. Beyond this particular case, I’m not a fan of whole life in just about any situation. Go figure then that half the people who attend the Million Dollar Round Table conferences generally sell a lot of this crap. Take from that what you will…
Brokers are licensed by the state or states in which they operate, and they are required to represent their clients’ best interests. This duty helps to ensure that a broker will steer clients to the best insurance for them, rather than to a particular company or to a specific policy. Brokers rely on repeat business from their clients, which also motivates them to make sure that their clients have the best possible coverage. In many cases, brokers may receive an additional commission if you renew your insurance plan — giving brokers an extra incentive to make sure that you have optimal coverage and that you are satisfied with your policies.

One point I would like to counter is the idea that whole life “is insurance that CANNOT BE TAKEN AWAY”. It can be taken away if you are not able to keep up with your premium payments, which is pretty common given that people’s lives and financial situations are constantly changing. With some policies, the premium can even go up depending on the performance of the policy, forcing you to pay more than expected if you want to keep the coverage in place. So it’s not quite as simple as saying that the death benefit is a sure thing.


Your “rent” analogy is a classic one used by life insurance salesmen when selling whole life, but it is a poor analogy. After all, insurance has nothing to do with renting vs. owning. Would you say that most people are simply “renting” auto insurance? Do you think people should buy auto insurance policies that will pay them the full price of a new car whenever their car dies, even if they drive it into the ground? Because that’s essentially what whole life insurance is. The main purpose of life insurance is to provide financially for dependents in the case that you die early, just as the main purpose of car insurance (beyond the liability portion) is to provide the financial value of your car in case it dies early. Once that financial protection is no longer needed, the insurance need is gone. Term insurance protects you while you need it and goes away once you don’t. It is insurance in the purest sense of the word and is by far the more effective way to go about it for the vast majority of the population.
Term life insurance is very simple. You pay a (typically) small premium for financial protection that lasts a specific amount of time, typically 10-30 years. It is pure insurance. The only potential benefit is the payout upon death. And in my opinion, this is the only type of life insurance that most people should consider, since the financial protection provided by the death benefit is the entire purpose of life insurance.

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Most people are familiar with or have worked with an insurance agent at some point in their lives. However, a broker has an entirely different role from an insurance agent. Unlike insurance agents, insurance brokers do not work for an insurance company. They work for their clients, providing advice on the best insurance options for their clients’ needs. Their goal is to support their clients’ interests — not to sell a particular policy on behalf of an insurance company.

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Weiner was talking about rolling returns for Vanguard. So, it’s his argument, not mine. And, this is a different issue from what you’re talking about anyway regarding annual returns based on monthy savings. So I’m not sure where you’re going with this or why you think it’s misleading. I believe Weiner got his figures from Vanguard…so…that would mean Vanguard is misleading itself? Doesn’t make sense man.
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I am looking into different investment options to start a retirement plan. What i have learned thus far, is that the majority of people seem to be looking at the total amount of the investment at the time of retirement. One of my primary concerns is the amount of taxation incurred once the funds start to be distributed. Deferred taxed 401K does not seem to be a viable option when you consider the taxation in say 30 years (even with the employer match) VS post-tax investments at the current tax rate. A Roth IRA seems to be a better option. I recently spoke to an advisor who recommended Whole Life as an investment option due to the non-taxable nature of the investment – i am currently researching how this may work. To your knowledge, has anyone performed a apples to apples comparison of the differing investment strategies to include estimated taxation at the time of disbursement?


Insurance brokers represent the insurance buyer – you the consumer or business owner.  They are appointed or contracted with multiple insurance companies.  They have the flexibility to discuss many options and companies that meet your needs and budget. Insurance brokers have been around as long as insurance agents.  In many cases people will refer to insurance brokers as independent insurance agents.
Using a broker can also simplify the process of picking insurance. There are so many different choices for insurance, with different limits and exclusions for each policy. It can be difficult to know which insurance and what level of coverage is right for you or your business. This is where an insurance broker can help. Using their experience in the field, a broker can analyze your risks and liabilities to determine exactly what coverage you need. With access to a variety of technology-based tools, brokers can make it simple to compare various options to determine which policies would best fit your needs. Using a broker eliminates the stress of learning about different types of insurance, and makes it easy to figure out what insurance will work for you.
Analysis: When a broker says that, it means another broker has made a submission to the insurer in your name. That’s most likely the incumbent broker. In fact, the incumbent may have submitted your name to 10 insurers — often, without your approval or even your knowledge. This is a disguise. The incumbent appears to be shopping for a better deal on your behalf, while the actual motive is to freeze out competitors.
Second, I used the policy illustration I received as an example of the kinds of policies I see all the time. Of course every policy is different and needs to be evaluated on its own merits, but the truth is that most of these policies behave similarly. The policy I evaluated personally was actually one of the good ones and was backed by one of the companies that many people look to as the “gold standard”. So it was not a “bad policy”. It was typical of one of the “better” policies.
The primary purpose of life insurance is to protect the people who are financially dependent upon you. Once those people are no longer dependent upon you (e.g. your kids grow up), you no longer have the need for that protection. Term life insurance is like having car insurance for as long as you own a car. Whole life insurance is like having car insurance forever, even when you no longer own a car.
If one were to buy a long dated bond with a yield of 4%, and interest rates go up, one could actually end up with a loss if bond not held to maturity. On the other hand, if one were to OVERFUND a participating Whole Life policy, the CASH VALUE IRR over 20 years would be around 4% (probably slightly above) based on current dividend scales. Yet if long term rates rise, so will the returns in the policy. As long as premiums are paid, the cash value in any given time will NEVER be less than the cash value a year earlier.
Backdoor Roths – 1) These vehicles are still capped at $5,500 on an annual basis (LI has no restrictions on contribution amounts.) 2) Roth IRAs are still exposed to market risk and can experience losses in account value (whole life policies are not and cannot). 3) Doing a backdoor conversion year after year is an administrative pain in the ass and will have tax implications if you hold a traditional IRA.
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.
It’s a great point about the cost causing people to be underinsured. I have no idea if there are any statistics on that, but intuitively it would seem to make sense. It’s a shame if someone with a real need for life insurance is under-protected because a salesman could make a bigger commission off the more expensive product. But I’m sure it happens.

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I disagree that an insurance policy has to pay for it to be valuable. Its purpose is to provide you with protection from scenarios you couldn’t otherwise handle, not to pay you money no matter what. Is your emergency fund worthless if you never have an emergency? Would you pay extra for an auto insurance policy that guaranteed you money for a brand new car (at the cost of the new car, not the value of your old on) once yours is done? Even if was more cost-efficient to save the money yourself? Again, I do agree that there are situations where the insurance component of a whole life policy can be valuable. I will never argue that it is a worthless product. I just think that many times it is sold to people who have options for meeting their needs in better ways. That doesn’t make it evil, just inefficient for many circumstances.
The first life table was written by Edmund Halley in 1693, but it was only in the 1750s that the necessary mathematical and statistical tools were in place for the development of modern life insurance. James Dodson, a mathematician and actuary, tried to establish a new company aimed at correctly offsetting the risks of long term life assurance policies, after being refused admission to the Amicable Life Assurance Society because of his advanced age. He was unsuccessful in his attempts at procuring a charter from the government.
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Thanks so much for the great article! My husband has a whole life insurance plan that was set up for him by his dad when he was a teenager, so he’s always had it. It’s expensive, though, and we’ve often talked about discontinuing it because it’s so pricey. Still not sure what the best route to take is, but I appreciate the very informative article!
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That’s a healthy viewpoint and I wish more agents shared it. However, I still don’t believe that it’s a helpful product for most people. There are many ways that those premiums could be put to use that would provide the flexibility to use the money for a funeral, etc., or to use it for other needs along the way, all without the rigidness of having to continue paying the premiums or else see the entire benefit disappear.
The issue of diversification eludes to a level of risk. However, the history of paid dividends over 50+ years for the companies I reviewed demonstrated extremely low risk, with standard deviation on dividend of 1.5. This is extremely low risk. Of the companies I reviewed the 30 year history of dividend ranged between 5.4% (lowest) to 13.3% (highest) .

Holly, I just turned seventy years old and retired and constantly looking and applying for jobs because my monthly income is only 1,206.00. I am divorce for only twenty eight years and have a learning disabled adult son who has never work. I need a life insurance policy to be around $30,000 to cover funeral expenses and some money for my son to cope. What life insurance company should I chose and should I chose term or whole life? I would greatly appreciate your response. I have no savings. Thank you. Diahann Cambridge

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James, be very careful about blanket advice to roll your pension into an IRA. A lot of financial professionals can make money through a transaction like that and you’d likely be giving up guaranteed income for the rest of your life. To be clear, it’s certainly possible that this would be a good move, but you would only know that after a careful and detailed analysis of your specific pension, your specific goals, and the rest of your financial situation.

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This shift to universal life by insurance companies has made premiums cheaper but removed many of the guarantees that came with traditional whole life insurance like guaranteed face amounts, guaranteed premiums and guaranteed cash values. The result is that there are a lot of underfunded universal life insurance policies out there which aren’t really permanent policies anymore since they can’t support themselves and will lapse instead of paying out.
I wish I could give you direct feedback but it’s really impossible to say Steve. It depends on your specific situation, your goals, and also the state of the policies as they exist now. Evaluating an in-force policy is different than evaluating a yet-to-be-purchased policy, and even a bad policy can perform reasonably well going forward once it’s been in place for a number of years. If you’d like an objective analysis, I would suggest reaching out to a fee-only financial planner. Given that you’re closer to retirement than my typical client, I would try to find one through NAPFA or Garrett Planning Network.
Regarding pension vs registered accounts: It is hard to know what is better, relying on your pension or relying on an individually held mutual fund account (or some variation thereof using other securities). This would require a close reading of the pension and securities legislation in your region. For us in Canada, a defined benefit pension (prescribed benefits upon retirement based on a formula where the employer is responsible for funding any shortfall) can be incredibly enticing due to the guarantees attached to them. It is the preferred pension and stacks up really well against defined contribution pensions (where employers match the contributions of employees to at least a certain degree and where the account grows until retirement and the pensioner draws down the account and is burdened with any shortfall) but defined benefit plans are going the way of the dodo over here. It’s still available to government employees but most private employers don’t want to take on the risk of having to meet funding requirements. That’s a huge liability on the balance sheet. In any case, pensions have a few benefits over individual savings vehicles. First, they benefit from reduced management fee pricing, thereby improving returns marginally over the course of fund accumulation. Second, they benefit from a longer investment horizon since they are always looking many years in the future as their pension liabilities are long-term by definition. Third, actuaries are required to evaluate pensions regularly to make sure funding targets are established and followed.
The sale of life insurance in the U.S. began in the 1760s. The Presbyterian Synods in Philadelphia and New York City created the Corporation for Relief of Poor and Distressed Widows and Children of Presbyterian Ministers in 1759; Episcopalian priests organized a similar fund in 1769. Between 1787 and 1837 more than two dozen life insurance companies were started, but fewer than half a dozen survived. In the 1870s, military officers banded together to found both the Army (AAFMAA) and the Navy Mutual Aid Association (Navy Mutual), inspired by the plight of widows and orphans left stranded in the West after the Battle of the Little Big Horn, and of the families of U.S. sailors who died at sea.
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Good questions. The honest answer is that the only way to know what’s best is to do a review of your personal goals, the policy you have now, the whole life policy you would be changing it to, and the other options available to you. I would highly recommend seeking out a fee-only financial planner who can help you with this, and I would start by looking at the Garrett Planning Network. Their advisors all offer hourly services that would be perfect for this kind of project. NAPFA is another great network of fee-only planners.
Hi Matt, I have a question for you. I was sold a whole life policy by a friend 4.5 years ago (before I was married) with the promise that it is a good investment tool. I’ve learned a lot about investing since then. The accumulation value is $6700 the surrender value is about $2700. I’m wondering if I should get out now and take the $2700 and run, or wait until I can pull out what I’ve paid into it which I hear is 10 years.

Global insurance premiums grew by 2.7% in inflation-adjusted terms in 2010 to $4.3 trillion, climbing above pre-crisis levels. The return to growth and record premiums generated during the year followed two years of decline in real terms. Life insurance premiums increased by 3.2% in 2010 and non-life premiums by 2.1%. While industrialised countries saw an increase in premiums of around 1.4%, insurance markets in emerging economies saw rapid expansion with 11% growth in premium income. The global insurance industry was sufficiently capitalised to withstand the financial crisis of 2008 and 2009 and most insurance companies restored their capital to pre-crisis levels by the end of 2010. With the continuation of the gradual recovery of the global economy, it is likely the insurance industry will continue to see growth in premium income both in industrialised countries and emerging markets in 2011.

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Thank you for your article and really speaking to the “lay person.” A lot of things in your article really make sense! I only wish I had read it before my husband and I both purchased whole life policies just last week fronting nearly $20,000 with annual payments of $10,000 for the next 24-years. Shame on us for not understanding the details better!
Full Circle, one time I thought whole life insurance was great. Then I cashed it in, bought at least 5 new automobiles, a house, a couple motorcycles and more bullshit. Then I learned how to properly use life insurance as a bank, instead of borrowing money from a bank, I borrow the money from myself and pay myself back what I would have paid banks. I get to collect all the interest I would have paid the banks. I get to grow my money tax free. I get to pass my hard earned money on to my family tax free. The key is understanding Whole life vs creating your own banking system.

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First, a term life insurance policy will cost much less than a whole life insurance policy with the same death benefit, often around 12 times less. So your example of a $30,000 whole life policy with a $20 premium compared to a $30,000 term life policy with that same $20 premium is not a valid comparison. The term life premium would be a fraction of the whole life premium.
Weiner was talking about rolling returns for Vanguard. So, it’s his argument, not mine. And, this is a different issue from what you’re talking about anyway regarding annual returns based on monthy savings. So I’m not sure where you’re going with this or why you think it’s misleading. I believe Weiner got his figures from Vanguard…so…that would mean Vanguard is misleading itself? Doesn’t make sense man.
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Through these educational requirements and experience in the field, brokers gain a significant level of knowledge in insurance. They are well informed about specific types of insurance and how claims of a particular type are covered. For example, a broker can explain to an individual exactly what types of risks a homeowner’s insurance policy will cover and what it will exclude (such as acts of god, intentional acts, negligent acts, slip and falls, loss of theft of valuable items, etc.). With this knowledge, clients can make better informed choices about what type of insurance they need, along with how much coverage is necessary. This is a broker’s job: to help clients understand the liabilities that they have and how those risks can be adequately managed through insurance. Brokers can then help clients review a number of insurance options to pick the policy and premium that best fits their needs and budget.


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The second is that I’ve heard enough horror stories about indexed life insurance in general to be skeptical. It’s not that it can’t work, it’s that there are plenty of examples of it underperforming, having a catch that wasn’t made clear up front, and other instances where it just doesn’t work the way it was sold to work. Any time something is sold as being able to pay for any financial goal no matter the market conditions, it’s usually too good to be true.
Recently, viatical settlements have created problems for life insurance providers. A viatical settlement involves the purchase of a life insurance policy from an elderly or terminally ill policy holder. The policy holder sells the policy (including the right to name the beneficiary) to a purchaser for a price discounted from the policy value. The seller has cash in hand, and the purchaser will realize a profit when the seller dies and the proceeds are delivered to the purchaser. In the meantime, the purchaser continues to pay the premiums. Although both parties have reached an agreeable settlement, insurers are troubled by this trend. Insurers calculate their rates with the assumption that a certain portion of policy holders will seek to redeem the cash value of their insurance policies before death. They also expect that a certain portion will stop paying premiums and forfeit their policies. However, viatical settlements ensure that such policies will with absolute certainty be paid out. Some purchasers, in order to take advantage of the potentially large profits, have even actively sought to collude with uninsured elderly and terminally ill patients, and created policies that would have not otherwise been purchased. These policies are guaranteed losses from the insurers' perspective.
Almost too much false information/lack of understanding here to even try to tackle. You do realize participating whole life/phantom loans are one of the MAIN ways that the wealthy keep their wealth, avoid taxation and funnel income into an investment vehicle right? The hiltons have been doing it for years as well as virtually every wealthy family manager out there. The lack of understanding most people have regarding these policies, is why they advise against them. They themselves do not understand.
4. The guaranteed dividend or return rate was 0.75% and the last time the company had to resort to this rate was in 2008. In 2013 and 2014 the return was 12%. The average return was 8% and the return was capped at 15%. This average return seemed better than whole life policies that I had read about. Your money was invested similar to any other moderate risk investment account and this was different from the conservative approach that I thought most whole life policies took.
Great read (http://momanddadmoney.com/insurance-and-investing-dont-play-well-together/ as well). Really taught me a lot. I’m a growing professional and a ‘friend’ tried to sell me a whole life participating life insurance. Like I believe you mention several times, all the ‘pros’ sounded really attractive. It actually made it sound stupid not to buy it. However, this alone made me hesitate as we all know what usually happens when something is too good to believe. I did a number of searches and read a few articles before stumbling on to yours. Excellently written providing a comprehensive explanation in terms that even a layman (i.e. me) could understand. Thank you as you just saved me from making a very big mistake. I hope others are lucky enough like me to happen upon your article before they make their decisions.
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Save your money… don’t invest it… unless you’ve first insured that even if those investments don’t work out. Life is a big enough investment as it is… especially if others are dependent on you and particularly if you become wealthy. Term insurance won’t cut it. It will almost certainly be lapsed by the time you really need it. Too many opportunities over a lifetime to miss a payment and then poof… it’s gone.
Your statements are somewhat misleading. The policies that Kim are describing are likely Universal Life policies, not true whole life policies. True whole life policies have set premiums, not increasing. And the cash value is built off of a dividend being paid by the insurance companies. Many insurance companies (Ohio National Northwestern ?Mutual, ect.) have been around for over 100 years and have literally paid a dividend every single year. Which means that the policy holder is paying the same premium every single year and is also experience growth in their cash value account very single year. When Kim says that her “cash value was not making good returns” she is referring to a policy that is tied to the market, not based off of dividend payments. Whole life is an amazing product that you are confusing with Universal Life
Almost too much false information/lack of understanding here to even try to tackle. You do realize participating whole life/phantom loans are one of the MAIN ways that the wealthy keep their wealth, avoid taxation and funnel income into an investment vehicle right? The hiltons have been doing it for years as well as virtually every wealthy family manager out there. The lack of understanding most people have regarding these policies, is why they advise against them. They themselves do not understand.
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.”
Calculable loss: There are two elements that must be at least estimable, if not formally calculable: the probability of loss, and the attendant cost. Probability of loss is generally an empirical exercise, while cost has more to do with the ability of a reasonable person in possession of a copy of the insurance policy and a proof of loss associated with a claim presented under that policy to make a reasonably definite and objective evaluation of the amount of the loss recoverable as a result of the claim. 

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