As a child, I was always threatened by Christmas. Santa is described by these frightening lines in the Christmas song:

He sees you when you’re sleeping
He knows when you’re awake
He knows if you’ve been bad or good
So be good for goodness’ sake!

And the moral? “So! You better watch out!”

Over my career in financial services, I often wondered if I were in fact doing “good for goodness’ sake.” Or, to be honest, doing good for my good. For mere personal gain. To receive acclamation.

Ethics in Financial Services
A sound measure of goodness is ethics.

In 2014 the Bank Negara Malaysia (BNM) and Securities Commission of Malaysia (SC) announced the formation of the Financial Services Professional Board (FSPB). The objective of the FSPB was to “drive the development and harmonization of professional standards across the banking and insurance industry, Islamic finance and capital markets, working closely with regulators and the professional bodies within the financial services sector.”¹

The financial services industry plays a central role in any economy. This is why, in 2018, the FSPB established the Professional Code for the International Financial Services Industry; basically, a shared commitment to a common set of values, designed to engender trust in the financial industry.

On May 24, 2018, Ms. Jessica Chew Cheng Lian, deputy governor of the Central Bank of Malaysia (Bank Negara Malaysia), gave the Welcome Address at the convention where the new FSPB Professional Code was launched. In her remarks she said:

“There is an acknowledgement that behavior is ultimately regulated by something that runs deeper than rulebooks. It is not an easy thing to put your finger on. Regulators have talked about ‘the way things get done’ in an institution, or ‘the human element in everyday decisions.’ We like to think of it as how one behaves when no one is watching.”²

Everyone, that is, including Santa.

Trust Is Rooted in Ethics
Here are the five principles contained in the Code of Ethics for The Financial Services Industry:

• Principle 1: Competence “Individuals across the financial services industry shall develop and maintain the relevant knowledge, skills and behavior to ensure that their activities are conducted professionally and proficiently. This includes acting with diligence, as well as obtaining, and regularly updating, the appropriate qualifications, training, expertise, and practical experience.”³
• Principle 2: Integrity “Organizations and individuals acrossthe financial services industry shall be honest and open in all their dealings. This includes behaving in an accountable and trustworthy manner, and avoiding any acts that might damage the reputation of, or bring discredit to, the industry at any time.”⁴
• Principle 3: Fairness “Organizations and individuals across the financial services industry shall act responsibly and embrace a culture of fairness and transparency. This includes treating those with whom they have professional relationships with respect and ensuring that they consider the impact of their decisions and actions towards all stakeholders.”⁵
• Principle 4: Confidentiality “Organizations and individuals across the financial services industry shall protect the confidentiality and sensitivity of information provided to them. This includes using it for its intended purposes only and not divulging information to any unauthorized persons, including third parties, without the necessary consent from those involved unless disclosure is required by law or regulation.”⁶
• Principle 5: Objectivity “Organizations and individuals across the financial services industry shall not allow any conflict of interest, bias, or undue influence of others to override their business and professional judgment. They shall declare, to those concerned, all matters that could impair their objectivity.”⁷

This is a good list. Santa would be pleased if all of us in the financial services industry, especially independent distribution, acted accordingly.

Point: In independent distribution we need to act ethically in order to strengthen the trust others place in us.

More than Ethics
On April 14, 1939, John Steinbeck published his novel The Grapes of Wrath. It had staggering success. Steinbeck wrote the 619-page novel in longhand, in a mere five months. His wife, Carol, prepared the typed manuscript. The book sold over 400,000 copies in its first year of publication. In its review, The New York Times wrote, The Grapes of Wrath is “a magnificent novel of America.” Because of the novel’s success and influence, Steinbeck received the Pulitzer Prize in Fiction in 1940.

Back then First Lady Eleanor Roosevelt wrote a nationally syndicated newspaper column, entitled “‘My Day,” which ran six days a week. In her column she wrote: “Now I must tell you that I have just finished a book which is an unforgettable experience in reading. The Grapes of Wrath by John Steinbeck both repels and attracts you. The horrors of the picture, so well-drawn, make you dread sometimes to begin the next chapter, and yet you cannot lay the book down or even skip a page.”⁸

In fact, the First Lady traveled to California to see for herself the living conditions at the labor camps that Steinbeck described. The Grapes of Wrath, and Ms. Roosevelt’s support, led to Congressional hearings about labor law reforms and wage regulation.

Steinbeck’s wife Carol not only typed the novel, but she also suggested the title. The Grapes of Wrath comes from the opening lines of Julia Ward Howe’s Battle Hymn of the Republic, published in 1862:

“Mine eyes have seen the glory of the coming of the Lord
He is trampling out the vintage where the grapes of wrath are stored
He hath loosed the fateful lightning of his terrible swift sword
His truth is marching on.”

Ms. Howe and her husband visited Washington, D.C. in November 1861. While there, Howe heard Union troops singing a marching song called John Brown’s Body, a song that glorified the abolitionist John Brown, a man who was convicted and hanged for murdering a family of planters, and for killing a group of U.S. Army soldiers at Harpers Ferry.

While Howe and her husband were both strong anti-slavery activists, there was something distasteful about heartily praising a murderer in song.

Howe wrote the new lyrics to the same tune the very next day. She took dead aim at slavery. One verse of the hymn includes the words “let us die to make men free.” This is a call to fight to end slavery.

After she had written the lyrics, Howe wrote in her diary that “something of importance” just took place. In fact, her poem and the popular tune became an important part of American culture. Battle Hymn of the Republic was sung at the funerals of Winston Churchill, Robert Kennedy, Richard Nixon, and Ronald Reagan. In 1963 Judy Garland sang it on national television in honor of John F. Kennedy. More recently, it was performed at the memorial services for the victims of 9/11 and at President Obama’s second Inaugural Address.

Point: Today we easily embrace ethical behavior, and we all roundly agree with ending slavery. Santa, again, would be pleased.

Grace that Runs Deeper than Rulebooks
But wait.

One might ask why Carol Steinbeck chose Battle Hymn of the Republic as the source of her husband’s book title.

Carol Steinbeck chose Battle Hymn of the Republic as the source of the title for her husband’s novel because, like Howe’s lyrics, The Grapes of Wrath tackles a huge social ill—the maltreatment of immigrants and the poor.

In the 1930’s, the Dust Bowl created intolerable living conditions for over a million people living in the Central Plains who migrated west to find work and establish life in places like California’s Central Valley. For many, the only choice they had was to leave, and they found themselves on Route 66 headed to California.

Once these throngs of impoverished people arrived, tensions ran hot between the migrant population and the established merchants, landowners, and middle class of the western states. There is a huge divide between ownership and aspiration.

Steinbeck: “The quality of owning freezes you forever in ‘I,’ and cuts you off forever from the ‘we.’”⁹

Greed and generosity are competing forces in the novel. Steinbeck portrays self-interest and altruism as equal and opposite powers. The rich are depicted as greedy, and the poor are presented as generous. The landowners and businessmen are blamed for upholding a system that keeps the poor families in poverty. The people in power kept prices controlled in order to increase profits. The employers created extreme competition for good-paying jobs in order to keep wages low.

The majority of people already living in the western states felt fear and anxiety as these hordes of people came looking for assistance and opportunities.

Every now and then Steinbeck describes the acts of kindness offered by ordinary people seeing the needs of others and feeling empathy. Acts of grace.

Point: There is something beyond ethical behavior. It is called grace.

There is an unfamiliar line in Battle Hymn of the Republic which states that to the extent that you fight slavery and its proponents, “so with you My grace shall deal.”

Independent Distribution and Immigration
In the United States we all see the spiraling immigration problem. Countless people are streaming across our borders. It will require the strength and wisdom of political leaders and other decision-makers to resolve the myriad issues involved with immigration. It is massively beyond anything we can address here.

However, the reality cannot be escaped that millions of migrating people are living within our borders, and they, like Steinbeck’s “Okies,” have traveled hard roads and are seeking to find work, settle into communities, and raise families. They are a challenge wherever they settle, but tensions, anxieties and fear ought not to preclude independent life insurance distribution from addressing the needs for our products that these newcomers have.

Let’s return to the words of Ms. Jessica Chew Cheng Lian.

• Something that runs deeper than rulebooks
• Something not easy to put your finger on
• The human element in everyday decisions

Deeper than Rulebooks
According to the ACLI: “Life insurers provide jobs, protect American families, and invest in the economy. 90 million American families count on life insurers’ products for protection, long term savings, and a guarantee of lifetime income when it’s time to retire. Given today’s economic uncertainties, the financial and retirement security these products provide has never been more important.”¹⁰

In 2022 Forbes Advisor conducted a survey on life insurance.11 It includes some interesting findings:

• Fewer than half of people without life insurance surveyed in this study say they feel financially secure.
• 44 percent of American households would encounter significant financial difficulties within half a year if they lost the primary wage earner in the family, and 28 percent would reach this point in only a month.
• 106 million American documented and naturalized adults do not believe they have adequate life insurance coverage, according to the 2022 Insurance Barometer Study conducted by LIMRA and Life Happens.¹²

Imagine what the statistics would be for the 11 million undocumented immigrants living in the United States. They also have to worry about taking care of their families after their deaths.

Immigrants have the same needs for life insurance as U.S. citizens:

• Income replacement
• College funding for dependents
• Debt cancellation

(Note: Purchasing life insurance is not illegal for an undocumented immigrant.)

Point: Undocumented persons are as much in need, if not more so, for the products offered by the life insurance industry.

Something Not Easy to Put Your Finger On
But can they actually acquire coverage? Are they excluded by the rulebooks?

Without proper paperwork and documentation, just about everything an undocumented immigrant does in the United States will be more difficult.

Life insurance offers many benefits to immigrant policy owners and their beneficiaries regardless of their citizen status. Life insurance rates are not impacted by immigration status. However, finding life insurance is not easy for people who are not U.S. citizens. Citizenship status will influence which life insurance companies will be able to provide coverage and what further information is required to acquire a policy.

Undocumented immigrants living in the United States do not have Social Security numbers. They do not have U.S. citizenship. How, then, can they apply for life insurance?
(Note: People entering the United States illegally, with no documentation whatsoever, are not able to get life insurance.)

Undocumented immigrants can use a tax identification number (ITIN) to apply for life insurance policies. (With numerous carriers.) An ITIN is issued by the IRS. With it, immigrants can open a bank account, file taxes, and purchase life insurance. An ITIN is not contingent upon citizenship, and life insurance companies normally do not ask any questions about a proposed insured’s immigration status. The ITIN is not an indication that a person is an undocumented immigrant. Many foreign nationals and other legal, non-U.S. residents utilize an ITIN. Using their ITINs, life insurance companies will search the immigrant’s medical history and review their background for criminal activity.

These are extremely useful documents for immigrants applying for life insurance:

• A valid driver’s license
• Documentation of the last-seen doctor visit
• Employment history and paycheck records
• A current, valid passport from the home country
• Other requirements:
• Must reside in the United States and provide an address
• Have a U.S. bank account

Life insurance company underwriters consider and approve undocumented immigrants based on:

• MIB
• Driving records
• Prescription drug history
• Health history
• Working status
• Lifestyle situations such as credit history
• Insurable need

While Federal law protects life insurance beneficiaries, and undocumented immigrants can receive death benefits from life insurance policies regardless of immigration status, certain government agencies may intervene due to immigration status.

Point: With special attention given to non-citizen status, immigrant persons can qualify for life insurance policies with some documentation.

The Human Element in Everyday Decisions
Undocumented immigrants are especially at risk if a spouse or partner dies unexpectedly. Typically, very few extended family members live nearby to help the deceased’s immediate family.

In addition, because they are just getting started in the United States, they generally do not have adequate financial reserves should an emergency happen.

Most immigrants are willing and able to pay one or two dollars per day for life insurance to help their surviving family and loved ones should they die. Life insurance is an important financial safety net for both U.S. citizens and immigrants to the United States.

Question: As an independent financial professional, are you open to helping people (who are technically illegal immigrants) in their pursuit to provide their families and loved ones with financial security through life insurance?

Application:

• How can you broaden your activities and offerings to attract and serve the immigrant population?
• Are your services discoverable by immigrant people living within your same geographic area?
• Are you willing to expand your marketing to cross language barriers and socio-economic differences?
• How can you enhance your networks by working cooperatively with agencies serving immigrants, with English as a second language services, and other organizations aligned with the concern for the present and future of these recently arrived families?
• What can you do to tailor your processes so that you serve this imperiled population?

Summary
Even children who came across America’s southern border illegally hope for Santa to find them. Santa is no respecter of borders. Nor does he inspect citizenship documentation.

Can we as an industry rise above politics, cross cultural barriers, and do what only we can do—provide financial security needed to anticipate the unexpected occurrences of death and disability?

Steinbeck: “Man, unlike any other thing organic or inorganic in the universe, grows beyond his work, walks up the stairs of his concepts, and emerges ahead of his accomplishments.”¹³
With grace as our motivation, let us walk up the stairs of the concepts that make our industry great!

Footnotes:

1. https://www.bnm.gov.my/-/announcement-on-the-formation-of-the-financial-services-professional-board-and-the-appointment-of-its-chairman-and-board-members.
2. https://www.bis.org/review/r180613c.htm.
3. https://www.maybank.com/iwov-resources/corporate_new/document/my/en/pdf/FSPB_Code_of_Ethics_PartA_B.pdf.
4. Ibid.
5. Ibid.
6. Ibid.
7. Ibid.
8. https://www.arts.gov/stories/blog/2020/ten-things-you-might-not-know-about-grapes-wrath.
9. “The Grapes of Wrath.” John Steinbeck, The Viking Press-James Lloyd, April 14, 1939.
10. https://www.acli.com/About-ACLI/Learn-More-About-the-Life-Insurance-Industry.
11. https://www.forbes.com/advisor/life-insurance/life-insurance-statistics/.
12. Life Happens: 2022 Insurance Barometer Study.
13. “The Grapes of Wrath.” John Steinbeck, The Viking Press-James Lloyd, April 14, 1939.