PPLI Portability Between Carriers: Options and Limitations

May 28, 2025
Colorful interlocking gears connected to yellow folders via blue pathways, illustrating PPLI portability mechanisms and transfer options between different Private placement life insurance carriers

Understanding Private placement life insurance (PPLI) portability between insurance carriers is essential for policyholders seeking flexibility in their wealth management strategies. PPLI portability options allow policyholders to transfer their policies from one carrier to another while maintaining tax-deferred status and policy benefits. However, significant limitations and considerations affect the feasibility and effectiveness of policy transfers, making careful evaluation crucial before initiating any portability transactions.

How Policy Transfers Work

The most common way to move PPLI policies between carriers is through 1035 exchanges, which allow you to transfer your policy while keeping the tax benefits intact. These exchanges let you move from one Private placement life insurance policy to another without paying taxes on any gains that have built up inside the policy. The transfer must follow specific IRS rules to qualify for this tax-free treatment, including having the money go directly from one carrier to the other.

When you make this type of transfer, your original investment basis carries over to the new policy, so you don’t lose the tax-deferred status of your accumulated gains. But the transfer process isn’t free – you might face surrender charges, administrative fees, and new underwriting requirements that can make the move expensive. The timing of your transfer matters too, since market conditions when you move can affect how much your investments are worth and whether the transfer makes financial sense.

What Carriers Will and Won’t Accept

Not every insurance company will accept transfers from other carriers, and each has its own rules about what types of policies they’ll take. Some carriers refuse transfers from certain competitors, while others have strict requirements about the kinds of policies they’ll accept through these exchanges. The investment options available with your new carrier might be completely different from what you had before, which could mean changing your entire investment strategy.

You might also need to go through new medical exams, financial reviews, or policy restructuring that could change your coverage amounts and premium payments. It’s important to check the financial strength of any carrier you’re considering, since moving to a weaker company could put your policy at risk down the road. Private placement life insurance carriers also differ significantly in their service levels and administrative capabilities, which affects your experience managing the policy over time.

Investment Options May Not Match

One of the biggest challenges with moving PPLI policies is that carriers offer different investment platforms. Your new carrier probably won’t have the exact same investment managers and strategies that your current policy offers, so you’ll likely need to restructure your investments during the transfer. This can be particularly challenging since Private placement life insurance policies often provide access to unique investment opportunities that aren’t available everywhere.

The minimum investment amounts and fee structures can vary a lot between carriers, which might make it impossible to continue with certain investment strategies after you transfer. Different carriers also have different investment committees and decision-making processes, so you might need to adjust how you oversee and manage your investments. The timing of moving your investments during the transfer can also expose you to market risks that could hurt your policy’s performance.

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Rules and Regulations to Consider

Transferring PPLI policies involves dealing with multiple regulatory agencies and state insurance departments, which can make the process complicated. Each state has its own rules about policy transfers, including how much notice you need to give, limits on surrender charges, and protections for consumers. Since these policies have investment components, securities regulations might also apply to the transfer process.

If you live outside the United States, you’ll face additional regulatory hurdles when transferring Private placement life insurance policies, including foreign reporting requirements and potential tax implications in multiple countries. You’ll also need to maintain compliance with private placement securities rules throughout the transfer to keep your policy’s special status and investment flexibility.

Counting the Real Costs

The true cost of transferring PPLI policies goes well beyond the obvious fees and surrender charges. Surrender charges can be substantial, especially if your policy is relatively new, and might be more than any benefits you’d get from switching carriers. New policies often come with setup fees and front-end charges that can further reduce the financial benefits of making a transfer.

You might also lose money during the transfer period because of market timing and the need to sell and reinvest your assets, which could even create taxable events inside your policy. Fee structures vary widely between carriers – some charge less ongoing fees but more upfront, while others have different arrangements entirely. Private placement life insurance policies typically have surrender charge periods that last for many years, making transfers financially impractical for a long time after you first buy the policy.

Other Ways to Make Changes

Before going through a full policy transfer, consider other options that might achieve what you want with fewer complications and lower costs. You might be able to modify your existing policy to meet changing needs without switching carriers entirely. Taking partial withdrawals, using policy loans, or changing your death benefit structure can give you access to cash or modify your policy without triggering transfer costs.

You could also consider buying additional PPLI policies with different carriers while keeping your existing policy, which gives you diversification and access to different investment platforms without disturbing your current arrangements. Sometimes changing policy ownership or setting up split-dollar arrangements can accomplish your restructuring goals more efficiently than switching carriers. Your current carrier might also offer policy riders or add-ons that provide the flexibility you need without requiring a complete transfer.

Making the Right Decision

Before moving forward with any PPLI transfer, you need to do thorough research to make sure the move will actually accomplish your goals and justify the costs involved. Run the numbers to compare the total cost of transferring against the projected benefits over your policy’s expected lifetime, including investment performance, fees, and tax implications. Carefully evaluate any new carrier’s financial strength, service quality, investment platform, and long-term stability.

Getting advice from legal and tax professionals is crucial to ensure you comply with all the rules and get the best tax treatment possible. Make sure the new carrier can handle your desired investment strategies and provide enough flexibility for future changes. Private placement life insurance transfers require careful timing to minimize market risks and maximize your chances of getting better results than you would by keeping your existing policy.

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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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