Congratulations. I'm not sure that this would work in US jurisdictions due to rules regarding discretionary clauses. See here:

https://www.erisadisabilitybenefits.com/longtermdisability/discretionaryclausesbannedinerisapolicies.html

https://www.erisapracticecenter.com/2017/11/district-court-applies-texas-ban-on-discretionary-clauses-in-insurance-contracts/

In addition to clearing that hurdle, I have some questions as it pertains to policyholders in the US and custody of funds issues. Specifically rule 206(4)-2. See here:

https://www.sec.gov/rules/final/ia-2176.htm#P57_4850

https://www.law.cornell.edu/cfr/text/17/275.206(4)-2

I have however solved both of these issues with my architecture. If you need help resolving these issues I'm more than happy to discuss.

Written by

Incentives architect for TandaPay

Get the Medium app

A button that says 'Download on the App Store', and if clicked it will lead you to the iOS App store
A button that says 'Get it on, Google Play', and if clicked it will lead you to the Google Play store