Kyle Busch Case: A day of reckoning for indexed universal life?
November 18, 2025 by John Hilton
Samuelson and Sheryl Moore, founder of Wink, Inc. and Moore Market Intelligence, joined forces in 2022 to author a letter to the National Association of Insurance Commissioners on the regulation of IUL.
The letter commented on Actuarial Guideline 49-A, one of several actions regulators have adopted to rein in IUL illustrations. Adopted in late 2020, AG 49-A barred IUL designs with multipliers or other enhancements from illustrating better than non-multiplier designs.
The Moore/Samuelson letter argued for more significant regulatory action, which has yet to occur. Some IUL fixed interest bonuses can generate illustrated income more than 60% higher than a base index such as the S&P 500, they wrote.
“This is, in our view, entirely inconsistent with the intent of regulators in crafting AG 49-A,” the letter reads. “The gamesmanship currently occurring in illustrations is similar in effect and pervasiveness to the buy-up caps and multipliers that proliferated after AG 49 and resulted in AG 49-A.”
Wink’s Moore on the Market: If you don’t know about the Busch IUL case, now is the time to get caught up on it. -sjm
