PPLI Policy Reviews: What to Evaluate When Assessing Performance

May 16, 2025
A financial professional in a navy suit analyzing a PPLI policy performance document with an upward-trending graph. The person is pointing to key metrics on the report while a pen holder sits nearby on the wooden desk, representing the thorough evaluation process required for Private Placement Life Insurance policy reviews.

Private Placement Life Insurance (PPLI) policies represent significant financial commitments that require regular assessment to ensure they continue meeting your wealth management objectives. Unlike retail insurance products, PPLI structures contain multiple components that influence overall performance and effectiveness. Understanding what to evaluate during policy reviews helps policyholders maximize benefits and address potential issues before they impact long-term results. This guide outlines the key elements to examine when assessing your PPLI policy’s performance.

Why Regular PPLI Reviews Matter

A properly structured PPLI policy serves as a tax-advantaged investment vehicle with insurance protection, but its effectiveness depends on ongoing monitoring and occasional adjustments. Market conditions change, tax laws evolve, and personal circumstances shift—all factors that can affect your policy’s performance and alignment with your financial goals. Conducting thorough reviews at regular intervals (typically annually) ensures your PPLI strategy remains optimized and continues delivering expected benefits.

These reviews provide opportunities to validate that your policy remains compliant with regulatory requirements, performs in line with projections, and continues supporting your wealth management strategy. Without regular assessment, policyholders risk diminished returns, missed opportunities for enhancement, or even potential tax complications that could undermine the policy’s central advantages.

Insurance Component Analysis

Death Benefit Structure and Adequacy

While investment performance often receives the most attention, the insurance component requires careful evaluation during reviews. Assess whether:

  • The death benefit amount remains appropriate for your estate planning needs
  • The type of death benefit option (level or increasing) continues to align with your objectives
  • The cost of insurance charges remains competitive compared to initial projections
  • The policy maintains compliance with life insurance corridor requirements

The death benefit structure directly impacts both protection value and policy expenses, making it a critical element in any comprehensive review.

Policy Expenses and Fee Structure

PPLI policies contain various fees that affect net returns, including mortality charges, administrative expenses, and asset-based fees. During reviews, compare actual expenses against:

  • Original expense projections from policy illustrations
  • Current market standards for similar PPLI structures
  • Alternatives available from other carriers or through policy modifications

As policies age and cash values grow, certain expense components may become more significant. A detailed expense analysis often reveals opportunities for negotiation or structural adjustments that can enhance long-term performance.

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Investment Performance Evaluation

Asset Allocation and Portfolio Construction

The investment component of your PPLI policy requires thorough assessment during reviews. Examine whether:

  • Current asset allocation remains aligned with your risk tolerance and investment goals
  • The portfolio construction effectively balances growth potential and risk management
  • The investment strategy continues to leverage the tax-advantaged environment optimally
  • Portfolio diversification adequately protects against market volatility

Policy reviews provide an opportunity to rebalance investments, adjust strategic allocations, or incorporate new asset classes that may benefit from the tax-efficient PPLI structure.

Manager Performance and Selection

If your policy utilizes external investment managers, evaluating their performance forms a crucial part of the review process. Consider:

  • Performance relative to appropriate benchmarks over multiple time periods
  • Risk-adjusted returns compared to peers and market standards
  • Consistency of investment approach and adherence to stated strategies
  • Fee levels relative to value provided and competitive alternatives

Underperforming managers or those whose approach no longer aligns with your objectives may warrant replacement, a process that should be carefully coordinated with your insurance consultant and the carrier.

Investment Account Structure

The technical structure of investment accounts within your PPLI policy affects both performance and flexibility. Review whether:

  • The number and allocation of separate account divisions remain appropriate
  • Account structures comply with diversification requirements
  • Trading restrictions or limitations impact investment execution
  • Cash positions and liquidity management enhance or detract from performance

Structural inefficiencies identified during reviews often present opportunities for optimization that improve long-term results.

Tax Efficiency Assessment

Current Tax Benefits Realization

The tax advantages of PPLI provide its primary appeal for many policyholders. During reviews, confirm that:

  • Tax-deferred growth continues without unexpected taxation events
  • The policy maintains its non-MEC (Modified Endowment Contract) status
  • Any withdrawals or loans have been structured to preserve tax advantages
  • Foreign tax considerations for international assets are properly addressed

Policy actions that trigger unexpected taxation can significantly undermine PPLI benefits, making tax compliance verification an essential review component.

Future Tax Optimization Opportunities

Beyond current compliance, reviews should identify opportunities to enhance future tax efficiency. Consider whether:

  • Policy funding strategies could be adjusted to improve tax outcomes
  • Asset location decisions between PPLI and other vehicles remain optimal
  • Roth conversion alternatives might complement your PPLI strategy
  • Basis step-up considerations align with your estate planning approach

As tax laws change and personal circumstances evolve, adjustment opportunities frequently emerge that can enhance overall tax efficiency.

Liquidity and Flexibility Evaluation

Access to Policy Value

PPLI policies should provide appropriate access to cash value when needed. During reviews, assess whether:

  • Policy loan provisions offer competitive terms and sufficient flexibility
  • Withdrawal options align with potential liquidity needs
  • Collateral assignment capabilities meet potential borrowing requirements
  • Surrender charges or limitations have changed or will change soon

Liquidity needs often evolve over time, making this assessment particularly important as policyholders approach retirement or other major life transitions.

Flexibility for Changing Circumstances

PPLI structures should adapt to changing personal and financial circumstances. Evaluate whether:

  • Premium payment flexibility meets current and anticipated cash flow situations
  • Policy adjustments can accommodate estate planning changes
  • Ownership structure continues to align with wealth transfer objectives
  • International flexibility addresses potential relocation or cross-border considerations

Limitations identified during flexibility reviews often highlight the need for structural adjustments or supplemental planning strategies.

Regulatory and Compliance Review

Insurance Regulation Compliance

Insurance regulations impact PPLI structures and require ongoing verification. Confirm that:

  • The carrier maintains appropriate licensing and financial stability
  • The policy complies with current insurance regulations in relevant jurisdictions
  • Any regulatory changes have been properly addressed in policy administration
  • Required filings and disclosures have been completed accurately

Regulatory compliance ensures the policy maintains its intended status and avoids potential complications with insurance authorities.

Tax Compliance Verification

Tax laws affecting PPLI continue evolving, necessitating regular compliance checks. Verify that:

  • The policy meets current diversification requirements
  • Investor control guidelines are being followed appropriately
  • Foreign asset reporting requirements have been satisfied
  • Any tax law changes have been evaluated for policy impact

Tax compliance issues identified early can often be addressed before they threaten the policy’s tax-advantaged status.

Carrier Assessment

Financial Strength and Stability

The insurance carrier’s ongoing viability directly affects policy security. During reviews, evaluate:

  • Current financial ratings from major rating agencies
  • Capital adequacy ratios and reserve requirements compliance
  • Parent company or reinsurance relationships that affect security
  • Regulatory interventions or concerns regarding the carrier

Carrier instability signals the potential need for policy transfer or replacement strategies before problems arise.

Service Quality and Administrative Support

Effective policy administration affects both performance and convenience. Assess whether:

  • Policy statements provide clear, comprehensive information
  • Service requests receive prompt, accurate responses
  • Online access tools meet your management and reporting needs
  • Administrative errors or delays have occurred since the last review

Service deficiencies often indicate the need for escalation with the carrier or consideration of alternative providers.

Integration with Overall Wealth Strategy

Alignment with Current Objectives

Personal goals and financial circumstances change over time. Reviews should confirm that:

  • The PPLI policy continues supporting your priority financial objectives
  • The balance between protection and investment remains appropriate
  • Policy performance contributes effectively to overall portfolio results
  • The strategy complements rather than conflicts with other planning vehicles

Misalignment often indicates the need for policy adjustments or broader wealth strategy revisions.

Coordination with Other Planning Vehicles

PPLI policies function within broader wealth management structures. Evaluate whether:

  • Integration with trust arrangements remains effective
  • Coordination with retirement accounts optimizes overall tax efficiency
  • Charitable planning strategies complement PPLI objectives
  • Business succession plans align with PPLI ownership and beneficiary designations

Coordination gaps frequently reveal opportunities for enhanced integration that improves overall results.

Documentation and Record-Keeping Verification

Policy Documentation Completeness

Proper documentation supports both management and potential claims. Confirm that:

  • Current policy contracts and amendments are properly maintained
  • Beneficiary designations remain current and clearly documented
  • Ownership arrangements are properly recorded and updated as needed
  • Transaction records are complete and accurately maintained

Documentation deficiencies should be addressed promptly to avoid future complications.

Reporting Accuracy and Completeness

Effective management requires reliable information. Verify that:

  • Performance reporting accurately reflects actual results
  • Tax reporting complies with current requirements
  • Cost basis tracking supports potential future distributions
  • External advisor reporting integrates effectively with policy information

Reporting inadequacies often indicate the need for enhanced tracking systems or carrier service improvements.

Conducting Effective PPLI Reviews

The Review Team Approach

PPLI reviews benefit from multidisciplinary expertise. Consider involving:

  • Your insurance consultant who specializes in PPLI structures
  • Investment advisors managing policy assets
  • Tax advisors familiar with insurance-based planning
  • Estate planning attorneys coordinating wealth transfer strategies

This team approach ensures comprehensive evaluation across all policy dimensions.

Review Frequency and Timing

While annual reviews provide a standard framework, certain triggers warrant additional assessment:

  • Significant market volatility affecting policy investments
  • Major tax law changes impacting insurance-based planning
  • Personal changes such as retirement, relocation, or family transitions
  • Carrier developments including ratings changes or merger activity

Timely reviews following these triggers help address emerging issues before they create significant complications.

Conclusion: Proactive Management Enhances PPLI Value

Private Placement Life Insurance policies represent substantial commitments that benefit from proactive management and regular assessment. Comprehensive reviews examining insurance components, investment performance, tax efficiency, liquidity provisions, regulatory compliance, carrier stability, strategy alignment, and documentation quality help ensure your PPLI structure continues delivering optimal value.

By approaching policy reviews systematically and addressing identified issues promptly, policyholders can enhance performance, maintain compliance, and adapt their PPLI strategy to evolving circumstances. This proactive approach maximizes the substantial benefits these specialized policies can provide when properly structured and managed.

At Colva Insurance Services, our experienced team provides comprehensive PPLI policy reviews that identify both opportunities and potential concerns.

Contact us to schedule a thorough assessment of your existing PPLI policy or to discuss implementing a new strategy optimized for your wealth management objectives.

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Rajiv Rebello

Rajiv Rebello

Author

Rajiv Rebello, FSA, CERA is the Principal and Chief Actuary of Colva Insurance Services. Colva helps family offices, RIAs, and high net worth individuals create better after-tax and risk-adjusted portfolio solutions through the use of life insurance vehicles and low-correlation alternative assets. He can be reached at [email protected].

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